Does the new five-year auditor rotation requirement include the years of service accumulated before the compliance date of the rule?
No, all external auditors are given a “clean slate” for purposes of the rotation requirement in ยง 621.32. An institution may not retain the services of lead and reviewing audit partners for more than five consecutive years, with the five-year clock starting on the first day of the 2008 fiscal year. The actual number of audits conducted or audit reports signed does not factor into the rotation calculation.
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