Independence Case

When Ramin was growing up in a small suburb of Boston, he was best friends with his cousin Saureb. Both boys played soccer on the same school team. Their parents even held joint birthday parties for them because their birthdays were two days apart.

Saureb’s family moved away from the Boston area when the boys were teenagers. Thereafter, they would email each other occasionally, but they grew apart from one another, as often happens in high school.

After graduating from college, Ramin went to work for a CPA firm in Waltham, Massachusetts and Saureb became the Assistant CFO at MassFin Bank in nearby Weyburn, Massachusetts. By coincidence, Ramin was assigned to work as a member of the team that was auditing MassFin Bank. (Ramin was excited to join this audit team because his mother had owned eight shares of this bank’s stock for many years and had always admired the bank’s financial success. Her holdings have tripled in value over her original $100 cost.)

Due to their physical proximity, Ramin and Saureb renewed their friendship and, like the old days, even began playing soccer together on fall weekends. Ramin lamented that he “probably should be spending time studying to pass the CPA exam instead of playing soccer,” but he loved the sportsmanship of playing soccer.

One weekend, Saureb told Ramin that an “awesome” job opening had become available in the bank’s Public Interest Entity Financial Reporting Department. Saureb clearly told Ramin that company policy was to advertise all job openings to the general public and that Saureb had “absolutely no pull” to get Ramin the job. Ramin applied nonetheless and was granted a first-round interview.

Because the interview was during the work day, Ramin “called in sick” that day and went to the job interview. He thought that the interview went well, and he was told that “callbacks” for the second round, if he were to make it to that level, would take place in about two weeks.  The interviewer took Ramin to lunch at a rather expensive sushi restaurant. Ramin expected the interviewer to pay for lunch, but Ramin nonetheless gestured that he would split the bill by placing his credit card on the table. MassFin Bank was the largest credit card issuer in the area, so not surprisingly, Ramin happened to have a MassFin credit card. The interviewer politely told Ramin to put his credit card away. She also told Ramin that she “made the big bucks” and had the “company’s blessing to pick up the lunch tab.” Ramin returned to his audit duties the following day, with renewed energy and excitement.

Is Ramin a covered member on the bank audit?

Is his cousin’s employment at the bank relevant to issues of independence?

1. Is his mother’s stock ownership in the bank relevant to issues of independence?
2. Is Ramin’s credit card ownership relevant to issues of independence?
3. Was Ramin’s free meal relevant to issues of independence?
4. What disclosures, if any, should Ramin have made to the CPA firm that employs him?
5. Would Ramin’s disclosure duties have been any different if he was interviewing for a position in New Business Development?
6. Respond to the above questions with an answer to the prompt that includes a justification for your response.