The AICPA has issued non-authoritative guidance which provides that auditing an SEC issuer’s financial statements and performing an independent private sector audit of a conflict minerals report would not be inconsistent with the SEC’s independence requirements under Rule 2-01 of Regulation S-X. The engagement to perform the independent private sector audit would nevertheless be considered a “nonaudit service” subject to audit committee pre- pursuant to Rule 2-01(c)(7) of Regulation S-X. In addition, the fees related to independent private sector audit would need to be included in the “All Other Fees” category of the principal accountant fee disclosures.
The guidance also addresses six other frequently asked questions. The AICPA has also prepared a matrix indicating what types of services related to the conflict mineral rules are prohibited.