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Federal Reserve Bank of Dallas
2200 N. PEARL ST.
DALLAS, TX 75201-2272

March 9, 2006
Notice 06-15

TO: The Chief Executive Officer of each
state member bank, bank holding company,
and foreign banking organization in the
Eleventh Federal Reserve District
SUBJECT
Interagency Advisory on the Unsafe and Unsound Use of
Limitation of Liability Provisions in External Audit Engagement Letters
DETAILS
The Federal Reserve and the other financial institutions regulatory agencies published on
February 9, 2006, an advisory to address safety and soundness concerns that may arise when
financial institutions enter into external audit contracts (typically referred to as “engagement
letters”) that limit the auditors’ liability for audit services.
The advisory is effective for audit engagement letters executed on or after February 9,
2006. The sdvisory does not apply to previously executed engagement letters.
ATTACHMENTS
A copy of the Board’s SR letter 06-4 dated March 1, 2006, and the interagency advisory
are attached.
MORE INFORMATION
For more information, please contact Richard Kiker, Banking Supervision Department,
(214) 922-6247. Previous Federal Reserve Bank notices are available on our web site at
www.dallasfed.org/banking/notices/index.html or by contacting the Public Affairs Department
at (214) 922-5254.

For additional copies, bankers and others are encouraged to use one of the following toll-free numbers in contacting the Federal
Reserve Bank of Dallas: Dallas Office (800) 333-4460; El Paso Branch Intrastate (800) 592-1631, Interstate (800) 351-1012;
Houston Branch Intrastate (800) 392-4162, Interstate (800) 221-0363; San Antonio Branch Intrastate (800) 292-5810.

BOARD OF GOVERNORS
OF THE

FEDERAL RESERVE SYSTEM
WASHINGTON, D. C. 20551

DIVISION OF BANKING
SUPERVISION AND
REGULATION

SR 06-4
March 1, 2006
TO THE OFFICER IN CHARGE OF SUPERVISION, APPROPRIATE
SUPERVISORY STAFF AT EACH FEDERAL RESERVE
BANK, AND BANKING ORGANIZATIONS SUPERVISED BY
THE FEDERAL RESERVE
SUBJECT: Interagency Advisory on the Unsafe and Unsound Use of Limitation of Liability
Provisions in External Audit Engagement Letters
The Federal Reserve and the other financial institutions regulatory agencies
published on February 9, 2006, the attached Advisory to address safety and soundness
concerns that may arise when financial institutions enter into external audit contracts
(typically referred to as "engagement letters") that limit the auditors' liability for audit services.
The Advisory informs financial institutions that it is unsafe and unsound to enter into
engagement letters for audits of financial statements, audits of internal control over financial
reporting, or attestations on management's assessment of internal control over financial
reporting which include provisions that (1) indemnify the external auditor against all claims
made by third parties, (2) hold harmless or release the external auditor from liability for claims
or potential claims that might be asserted by the client financial institution (other than claims
for punitive damages), or (3) limit the remedies available to the client financial institution (other
than punitive damages).
The Advisory is effective for audit engagement letters executed on or after
February 9, 2006. The Advisory does not apply to previously executed engagement letters.
However, the agencies encourage any financial institution subject to a multi-year audit
engagement letter containing unsafe and unsound limitation of liability provisions to seek to
amend its engagement letter to be consistent with the Advisory for periods ending in 2007 or
later.
This letter and the attached guidance should be distributed to state member
banks, bank holding companies, and foreign banking organizations supervised by the Federal
Reserve as well as to supervisory and examination staff. Questions pertaining to this letter
should be addressed to Terrill Garrison, Supervisory Financial Analyst, (202) 452-2712 or
Nina Nichols, Assistant Director, (202) 452-2961.
Richard Spillenkothen

1 of 2

Director

Attachment:

2 of 2

Interagency Advisory on the Unsafe and Unsound Use of
Limitation of Liability Provisions in External Audit Engagement
Letters (916 KB PDF)

INTERAGENCY ADVISORY ON THE UNSAFE AND UNSOUND USE OF
LIMITATION OF LIABILITY PROVISIONS
IN EXTERNAL AUDIT ENGAGEMENT LETTERS

PURPOSE
This Advisory, issued jointly by the Office of Thrift Supervision (OTS), the
Board of Governors of the Federal Reserve System (Board), the Federal Deposit
Insurance Corporation (FDIC), the National Credit Union Administration (NCUA), and
the Office of the Comptroller of the Currency (OCC) (collectively, the "Agencies"),
1]
alerts financialinstitutions'[SeeFootnote
boards of directors, audit committees, management, and
external auditors to the safety and soundness implications of provisions that limit external
auditors' liability in audit engagements.
Limits on external auditors' liability may weaken the external auditors'
objectivity, impartiality, and performance and, thus, reduce the Agencies' ability to rely
on Audits. Therefore, certain limitation of liability provisions (described in this Advisory
and Appendix A) are unsafe and unsound. In addition, such provisions may not be
consistent with the auditor independence standards of the U.S. Securities and Exchange
Commission (SEC), the Public Company Accounting Oversight Board (PCAOB), and the
American Institute of Certified Public Accountants (AICPA).
SCOPE
This Advisory applies to engagement letters between financial institutions and
external auditors with respect to financial statement audits, audits of internal control over
financial reporting, and attestations on management's assessment of internal control over
financial reporting (collectively, "Audit" or "Audits").
This Advisory does not apply to:
•
•
•
•

Non-Audit services that may be performed by financial institutions'
external auditors;
Audits of financial institutions' 401K plans, pension plans, and other
similar audits;
Services performed by accountants who are not engaged to perform
financial institutions' Audits (e.g., outsourced internal audits, loan
reviews); and
Other service providers (e.g., software consultants, legal advisors).

While the Agencies have observed several types of limitation of liability
provisions in external Audit engagement letters, this Advisory applies to any agreement
that a financial institution enters into with its external auditor that limits the external
Footnote 1

--As used in this document, the term financial institutions includes banks, bank holding companies, savings
associations, savings and loan holding companies, and credit unions.[EndofFootnote1]

Page 1 of 11

auditor's liability with respect to Audits in an unsafe and unsound manner.

BACKGROUND
A properly conducted audit provides an independent and objective view of the
reliability of a financial institution's financial statements. The external auditor's
objective in an audit is to form an opinion on the financial statements taken as a whole.
When planning and performing the audit, the external auditor considers the financial
institution's internal control over financial reporting. Generally, the external auditor
communicates any identified deficiencies in internal control to management, which
enables management to take appropriate corrective action. In addition, certain financial
institutions are required to file audited financial statements and internal control
audit/attestation reports with one or more of the Agencies. The Agencies encourage
financial institutions not subject to mandatory audit requirements to voluntarily obtain
audits of their financial statements. The Federal Financial Institutions Examination
Council's (FFIEC) Interagency Policy Statement on External Auditing Programs of
Banks and Savings Associations[Se Fo tnot2]notes, "[a]n institution's internal and external audit
e
programs are critical to its safety and soundness." The Policy also states that an effective
external auditing program "can improve the safety and soundness of an institution
substantially and lessen the risk the institution poses to the insurance funds administered
by the Federal Deposit Insurance Corporation (FDIC)."
Typically, a written engagement letter is used to establish an understanding
between the external auditor and the financial institution regarding the services to be
performed in connection with the financial institution's audit. The engagement letter
commonly describes the objective of the audit, the reports to be prepared, the
responsibilities of management and the external auditor, and other significant
arrangements (e.g., fees and billing). The Agencies encourage boards of directors, audit
committees, and management to closely review all of the provisions in the audit
engagement letter before agreeing to sign. As with all agreements that affect a financial
institution's legal rights, legal counsel should carefully review audit engagement letters to
help ensure that those charged with engaging the external auditor make a fully informed
decision.
While the Agencies have not observed provisions that limit an external auditor's
liability in the majority of external audit engagement letters reviewed, they have observed
a significant increase in the types and frequency of these provisions. These provisions
take many forms, making it impractical to provide an all-inclusive list. This Advisory
describes the types of objectionable limitation of liability provisions and provides
examples.[See Footnote 3]
Financial institutions' boards of directors, audit committees, and management
should also be aware that certain insurance policies (such as error and omission policies
Footnote 2

--Published in the Federal Register on September 28, 1999 (64 FR 52319). The NCUA, a member of the
FFIEC, has not adopted the policy statement.[EndofFootnote2]
Footnote 3
--Examples of auditor limitation of liability provisions are illustrated in Appendix A.[EndofFootnote3]

Page 2 of 11

and director and officer liability policies) might not cover losses arising from claims that
are precluded by limitation of liability provisions.
LIMITATION OF LIABILITY PROVISIONS
The provisions the Agencies deem unsafe and unsound can be generally
categorized as an agreement by a financial institution that is a client of an external auditor
to:
• Indemnify the external auditor against claims made by third parties;
• Hold harmless or release the external auditor from liability for claims or
potential claims that might be asserted by the client financial institution,
other than claims for punitive damages; or
• Limit the remedies available to the client financial institution, other than
punitive damages.
Collectively, these categories of provisions are referred to in this Advisory as "limitation
of liability provisions."
Provisions that waive the right of financial institutions to seek punitive damages
from their external auditor are not treated as unsafe and unsound under this Advisory.
Nevertheless, agreements by clients to indemnify their auditors against any third party
damage awards, including punitive damages, are deemed unsafe and unsound under this
Advisory. To enhance transparency and market discipline, public financial institutions
that agree to waive claims for punitive damages against their external auditors may want
to disclose annually the nature of these arrangements in their proxy statements or other
public reports.
Many financial institutions are required to have their financial statements audited
while others voluntarily choose to undergo such audits. For example, banks, savings
associations, and credit unions with $500 million or more in total assets are required to
have annual independentaudits.[SeeFootnot4]Certain savings associations (for example, those with a
e
CAMELS rating of 3, 4, or 5) and savings and loan holding companies are also required
by OTS regulations to have annual independentaudits.[SeeFootnot5]Furthermore, financial
e
6]
institutions that are publiccompanies[SeeFootnote must have annual independent audits. The
Agencies rely on the results of Audits as part of their assessment of the safety and
soundness of a financial institution.
In order for Audits to be effective, the external auditors must be independent in
both fact and appearance, and must perform all necessary procedures to comply with
Footnote 4

--For banks and savings associations, see Section 36 of the Federal Deposit Insurance Act (FDI Act) (12
U.S.C. 183 lm) and Part 363 of the FDIC's regulations (12 CFR Part 363). For credit unions, see Section
202(a)(6) of the Federal Credit Union Act (12 U.S.C. 1782(a)(6)) and Part 715 of the NCUA's regulations
(12 CFR Part 715).[EndofFootnote4]
Fooatnote 5
--See OTS regulation at 12 CFR 562.4.[EndofFootnote5]
Footnote 6
--Public companies are companies subject to the reporting requirements of the Securities Exchange Act of
1934.[EndofFootnote6]

Page 3 of 11

auditing and attestation standards established by either the AICPA or, if applicable, the
PCAOB. When financial institutions execute agreements that limit the external auditors'
liability, the external auditors' objectivity, impartiality, and performance maybe
weakened or compromised, and the usefulness of the Audits for safety and soundness
purposes may be diminished.
By their very nature, limitation of liability provisions can remove or greatly
weaken external auditors' objective and unbiased consideration of problems encountered
in audit engagements and may diminish auditors' adherence to the standards of
objectivity and impartiality required in the performance of Audits. The existence of such
provisions in external audit engagement letters may lead to the use of less extensive or
less thorough procedures than would otherwise be followed, thereby reducing the
reliability of Audits. Accordingly, financial institutions should not enter into external
audit arrangements that include unsafe and unsound limitation of liability provisions
identified in this Advisory, regardless of (1) the size of the financial institution, (2)
whether the financial institution is public or not, or (3) whether the external audit is
required or voluntary.
AUDITOR INDEPENDENCE
Currently, auditor independence standard-setters include the SEC, PCAOB, and
AICPA. Depending upon the audit client, an external auditor is subject to the
independence standards issued by one or more of these standard-setters. For all credit
unions under the NCUA's regulations, and for other non-public financial institutions that
are not required to have annual independent audits pursuant to either Part 363 of the
FDIC's regulations or § 562.4 of the OTS's regulations, the Agencies' rules require only
that an external auditor meet the AICPA independence standards; they do not require the
financial institution's external auditor to comply with the independence standards of the
SEC and the PCAOB.
In contrast, for financial institutions subject to the audit requirements either in
Part 363 of the FDIC's regulations or in § 562.4 of the OTS's regulations, the external
auditor should be in compliance with the AICPA's Code of Professional Conduct and
meet the independence requirements and interpretations of the SEC and itsstaf .[SeeFootnot7]In this
e
regard, in a December 13, 2004, Frequently Asked Question (FAQ) on the application of
the SEC's auditor independence rules, the SEC staff reiterated its long-standing position
that when an accountant and his or her client enter into an agreement which seeks to
provide the accountant immunity from liability for his or her own negligent acts, the
accountant is not independent. The FAQ also states that including in engagement letters
a clause that would release, indemnify, or hold the auditor harmless from any liability and
costs resulting from knowing misrepresentations by management would impair the

Footnote 7

--See FDIC Regulation 12 CFR Part 363, Appendix A—Guidelines and Interpretations; Guideline 14, Role
of the Independent Public Accountant - Independence; and OTS Regulation 12 CFR 562.4(d)(3)(i),
Qualifications for independent public accountants.[EndofFootnote7]

Page 4 of 11

8]
auditor'sindependence.[SeeFootnote
The SEC's FAQ is consistent with Section 602.02.f.i.
(Indemnification by Client) of the SEC's Codification of Financial Reporting Policies.
(Section 602.02.f.i. and the FAQ are included in Appendix B.)

Based on this SEC guidance and the Agencies' existing regulations, certain limits
on auditors' liability are already inappropriate in audit engagement letters entered into by:
•
•
•

Public financial institutions that file reports with the SEC or with the
Agencies;
Financial institutions subject to Part 363; and
Certain other financial institutions that OTS regulations (12 CFR 562.4)
require to have annual independent audits.

In addition, certain of these limits on auditors' liability may violate the AICPA
independence standards. Notwithstanding the potential applicability of auditor
independence standards, the limitation of liability provisions discussed in this Advisory
present safety and soundness concerns for all financial institution Audits.
ALTERNATIVE DISPUTE RESOLUTION AGREEMENTS AND JURY TRIAL
WAIVERS
The Agencies have observed that some financial institutions have agreed in
engagement letters to submit disputes over external audit services to mandatory and
binding alternative dispute resolution, binding arbitration, other binding non-judicial
dispute resolution processes (collectively, "mandatory ADR") or to waive the right to a
jury trial. By agreeing in advance to submit disputes to mandatory ADR, financial
institutions may waive the right to full discovery, limit appellate review, or limit or waive
other rights and protections available in ordinary litigation proceedings.
The Agencies recognize that mandatory ADR procedures and jury trial waivers
may be efficient and cost-effective tools for resolving disputes in some cases.
Accordingly, the Agencies believe that mandatory ADR or waiver of jury trial provisions
in external Audit engagement letters do not present safety and soundness concerns,
provided that the engagement letters do not also incorporate limitation of liability
provisions. The Agencies encourage institutions to carefully review mandatory ADR and
jury trial provisions in engagement letters, as well as any agreements regarding rules of
procedure, and to fully comprehend the ramifications of any agreement to waive any
available remedies. Financial institutions should ensure that any mandatory ADR
provisions in Audit engagement letters are commercially reasonable and:
Footnote 8

--In contrast to the SEC's position, AICPA Ethics Ruling 94 (ET §191.188-189) currently concludes that
indemnification for "knowing misrepresentations by management" does not impair independence. On
September 15, 2005, the AICPA published for comment its proposed interpretation of its auditor
independence standards. In that proposal the AICPA specifically identified limitation of liability
provisions that impair auditor independence under the AICPA's standards. Most of the provisions cited in
this Advisory were deemed to impair independence in the AICPA's proposed interpretation. At this
writing, the AICPA has not issued a final interpretation.[EndofFootnote8]

Page 5 of 11

•
•
•

Apply equally to all parties;
Provide a fair process (e.g., neutral decision-makers and appropriate
hearing procedures); and
Are not imposed in a coercive manner.

CONCLUSION
Financial institutions' boards of directors, audit committees, and management
should not enter into any agreement that incorporates limitation of liability provisions
with respect to Audits. In addition, financial institutions should document their business
rationale for agreeing to any other provisions that limit their legal rights.
This Advisory applies to engagement letters executed on or after February 9,
2006. The inclusion of limitation of liability provisions in external Audit engagement
letters and other agreements that are inconsistent with this Advisory will generally be
considered an unsafe and unsound practice. The Agencies' examiners will consider the
policies, processes, and personnel surrounding a financial institution's external auditing
program in determining whether (1) the engagement letter covering external auditing
activities raises any safety and soundness concerns, and (2) the external auditor maintains
appropriate independence regarding relationships with the financial institution under
relevant professional standards. The Agencies may take appropriate supervisory action if
unsafe and unsound limitation of liability provisions are included in external Audit
engagement letters or other agreements related to Audits that are executed (accepted or
agreed to by the financial institution) on or after February 9, 2006.

Page 6 of 11

APPENDIX A
Examples of Unsafe and Unsound Limitation of Liability Provisions
Presented below are some of the types of limitation of liability provisions (with an
illustrative example of each type) that the Agencies observed in financial institutions'
external audit engagement letters. The inclusion in external Audit engagement letters or
agreements related to Audits of any of the illustrative provisions (which do not represent
an all-inclusive list) or any other language that would produce similar effects is
considered an unsafe and unsound practice.
1. "Release from Liability for Auditor Negligence" Provision
In this type of provision, the financial institution agrees not to hold the audit firm
liable for any damages, except to the extent determined to have resulted from willful
misconduct or fraudulent behavior by the audit firm.
Example: In no event shall [the audit firm] be liable to the Financial Institution,
whether a claim be in tort, contract or otherwise, for any consequential, indirect, lost
profit, or similar damages relating to [the audit firm 'sj services provided under this
engagement letter, except to the extent finally determined to have resultedfrom the willful
misconduct or fraudulent behavior of [the audit firm] relating to such services.
2. "No Damages" Provision
In this type of provision, the financial institution agrees that in no event will the
external audit firm's liability include responsibility for any compensatory (incidental
or consequential) damages claimed by the financial institution.
Example: In no event will [the audit firm's] liability under the terms of this
Agreement include responsibility for any claimed incidental or consequential damages.
3. "Limitation of Period to File Claim" Provision
In this type of provision, the financial institution agrees that no claim will be
asserted after a fixed period of time that is shorter than the applicable statute of
limitations, effectively agreeing to limit the financial institution's rights in filing a
claim.
Example: It is agreed by the Financial Institution and [the audit firm] or any
successors in interest that no claim arising out of services rendered pursuant to this
agreement by, or on behalf of the Financial Institution shall be asserted more than two
years after the date of the last audit report issued by [the audit firm].
4. "Losses Occurring During Periods Audited" Provision

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In this type of provision, the financial institution agrees that the external audit
firm's liability will be limited to any losses occurring during periods covered by the
external audit, and will not include any losses occurring in later periods for which the
external audit firm is not engaged. This provision may not only preclude the
collection of consequential damages for harm in later years, but could preclude any
recovery at all. It appears that no claim of liability could be brought against the
external audit firm until the external audit report is actually delivered. Under such a
clause, any claim for liability thereafter might be precluded because the losses did not
occur during the period covered by the external audit. In other words, it might limit
the external audit firm's liability to a period before there could be any liability. Read
more broadly, the external audit firm might be liable for losses that arise in
subsequent years only if the firm continues to be engaged to audit the client's
financial statements in those years.
Example: In the event the Financial Institution is dissatisfied with [the audit
firm 'sj services, it is understood that [the audit firm 'sj liability, if any, arising from this
engagement will be limited to any losses occurring during the periods covered by [the
audit firm 'sj audit, and shall not include any losses occurring in later periods for which
[the audit firm] is not engaged as auditors.
5. "No Assignment or Transfer" Provision
In this type of provision, the financial institution agrees that it will not assign or
transfer any claim against the external audit firm to another party. This provision
could limit the ability of another party to pursue a claim against the external auditor
in a sale or merger of the financial institution, in a sale of certain assets or a line of
business of the financial institution, or in a supervisory merger or receivership of the
financial institution. This provision may also prevent the financial institution from
subrogating a claim against its external auditor to the financial institution's insurer
under its directors' and officers' liability or other insurance coverage.
Example: The Financial Institution agrees that it will not, directly or indirectly,
agree to assign or transfer any claim against [the audit firm] arising out of this
engagement to anyone.
6. "Knowing Misrepresentations by Management" Provision
In this type of provision, the financial institution releases and indemnifies the
external audit firm from any claims, liabilities, and costs attributable to any knowing
misrepresentation by management.
Example: Because of the importance of oral and written management
representations to an effective audit, the Financial Institution releases and indemnifies
[the audit firm] and its personnel from any and all claims, liabilities, costs, and expenses
attributable to any knowing misrepresentation by management.

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7. "Indemnification for Management Negligence" Provision
In this type of provision, the financial institution agrees to protect the external
auditor from third party claims arising from the external audit firm's failure to
discover negligent conduct by management. It would also reinforce the defense of
contributory negligence in cases in which the financial institution brings an action
against its external auditor. In either case, the contractual defense would insulate the
external audit firm from claims for damages even if the reason the external auditor
failed to discover the negligent conduct was a failure to conduct the external audit in
accordance with generally accepted auditing standards or other applicable
professional standards.
Example: The Financial Institution shall indemnify, hold harmless and defend
[the audit firm] and its authorized agents, partners and employees from and against any
and all claims, damages, demands, actions, costs and charges arising out of or by
reason of, the Financial Institution's negligent acts or failure to act hereunder.
8. "Damages Not to Exceed Fees Paid" Provision
In this type of provision, the financial institution agrees to limit the external
auditor's liability to the amount of audit fees the financial institution paid the external
auditor, regardless of the extent of damages. This may result in a substantial
unrecoverable loss or cost to the financial institution.
Example: [The audit firm] shall not be liable for any claim for damages arising
out of or in connection with any services provided herein to the Financial Institution in
an amount greater than the amount of fees actually paid to [the audit firm] with respect
to the services directly relating to and forming the basis of such claim.
Note: The Agencies also observed a similar provision that limited damages to a
predetermined amount not related to fees paid.

Page 9 of 11

APPENDIX B
SEC's Codification of Financial Reporting Policies, Section 602.02.f.i
and the SEC's December 13,2004, FAQ on Auditor Independence
Section 602.02.f.i - Indemnification by Client, 3 Fed. Sec. L. (CCH) f 38,335, at
38,603-17 (2003):
Inquiry was made as to whether an accountant who certifies
financial statements included in a registration statement or annual report
filed with the Commission under the Securities Act or the Exchange Act
would be considered independent if he had entered into an indemnity
agreement with the registrant. In the particular illustration cited, the board
of directors of the registrant formally approved the filing of a registration
statement with the Commission and agreed to indemnify and save
harmless each and every accountant who certified any part of such
statement, "from any and all losses, claims, damages or liabilities arising
out of such act or acts to which they or any of them may become subject
under the Securities Act, as amended, or at "common law,' other than for
their willful misstatements or omissions."
When an accountant and his client, directly or through an affiliate,
have entered into an agreement of indemnity which seeks to assure to the
accountant immunity from liability for his own negligent acts, whether of
omission or commission, one of the major stimuli to objective and
unbiased consideration of the problems encountered in a particular
engagement is removed or greatly weakened. Such condition must
frequently induce a departure from the standards of objectivity and
impartiality which the concept of independence implies. In such difficult
matters, for example, as the determination of the scope of audit necessary,
existence of such an agreement may easily lead to the use of less extensive
or thorough procedures than would otherwise be followed. In other cases
it may result in a failure to appraise with professional acumen the
information disclosed by the examination. Consequently, the accountant
cannot be recognized as independent for the purpose of certifying the
financial statements of the corporation. (Emphasis added.)
U.S. Securities and Exchange Commission; Office of the Chief Accountant:
Application of the Commission's Rules on Auditor Independence Frequently Asked
Questions; Other Matters - Question 4 (issued December 13,2004):
Q: Has there been any change in the Commission's long standing view
(Financial Reporting Policies - Section 600 - 602.02.f.i. "Indemnification
by Client") that when an accountant enters into an indemnity agreement
with the registrant, his or her independence would come into question?

Page 10 of 11

A: No. When an accountant and his or her client, directly or through an
affiliate, enter into an agreement of indemnity that seeks to provide the
accountant immunity from liability for his or her own negligent acts,
whether of omission or commission, the accountant is not independent.
Further, including in engagement letters a clause that a registrant would
release, indemnify or hold harmless from any liability and costs resulting
from knowing misrepresentations by management would also impair
the firm's independence. (Emphasis added.)

Page 11 of 11


Federal Reserve Bank of St. Louis, One Federal Reserve Bank Plaza, St. Louis, MO 63102