A guide to independence for family members of PwC professionals.
Personal Independence - #FamilyMatters
Thank you for visiting this site, created specifically for family members of PwC professionals.
Independence is a fundamental element of everyone’s role at PwC and it impacts the financial decisions people make, including family members.
We understand that the rules we have to follow aren’t always easy to understand. This site has been designed to explain and help you navigate what it means to be associated with someone who works at PwC and why you need to follow the same financial independence rules. It is important to help you understand personal independence, which is key to fulfilling PwC’s professional responsibilities.
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Personal independence guide for PwC professionals family members
What is personal independence?
At PwC, we offer assurance services that lend credibility to our clients' information. For an audit or assurance report to be valuable, users of the reports must trust that PwC, as the audit firm, remains uninfluenced by any relationships or situations that could compromise our objectivity. Independence pertains to the various types of relationships that the firm and our people are allowed to have with audit and assurance clients.
To be personally independent means PwC professionals must monitor their financial interests, other financial arrangements and relationships, including:
To support compliance, our PwC professionals are required to maintain an inventory of financial interests for themselves and immediate family members in the firm’s tracking tool, Checkpoint. Although other financial arrangements are not recorded in Checkpoint, an inventory of these relationships is also important as there may be independence implications as well.
For more information on what is required to be monitored, your PwC professional has access to a publication called “Check What’s in your Checkpoint” and the Global Independence Policy.
Is this information relevant to me?
Some of the rules the PwC professional has to comply with also impact ‘Immediate Family Members’. So, who does this include? Immediate family members include:
- Spouse
- Spousal equivalent: Someone the PwC professional lives with and shares a relationship with generally equivalent to that of a spouse and occurs at the point in time (first day cohabitation) when living together begins regardless of whether their finances are handled separately.
- Dependent: All dependent children, including stepchildren, who are either minors or financially dependent adult children, parents or other relatives who receive substantial financial support and over whom significant influence is exercised.
Why independence matters
Complying with PwC’s Personal Independence policy will help protect our people and the firm from reputational risk and significant penalties.
Protect
Help protect against any regulatory issues and potential personal reputational damage.
Preserve Investments
Compliance with Independence policy keeps you in control of your permitted investment relationships.
Build trust
Ensuring all our PwC professionals are independent helps us to maintain and build trust in society.
Why we need your help
If you are an ‘immediate family member’, your financial interests, other financial arrangements and personal relationships need to be known and monitored by your PwC professional. This is important because:
- It ensures your financial interests, other financial arrangements and personal relationships are permissible and do not potentially impact the firm and PwC professional's independence and the ability to work on certain clients.
- An inadvertent failure to comply with these standards can expose PwC to legal and regulatory risk or a loss of public confidence in our work.
- Remaining independent provides assurance to our audit clients and maintains public confidence in capital markets.
- There could be consequences for your PwC professional if these standards are not met.
What tools are used to monitor compliance
Checkpoint:
This is PwC’s personal independence software tool to monitor financial interests. PwC professionals considered practice staff members at manager level and above are required to maintain a portfolio in Checkpoint, and periodically confirm it is complete and accurate. To avoid entering impermissible financial relationships, PwC professionals should pre-clear financial holdings before acquiring them to ensure they are permissible to hold and do not impact their independence. It is required to record new holdings or full disposals within 14 days of the transaction. Note: Checkpoint does not track amounts or values, only the existence of a financial interests such as a holding of a mutual fund or shares.
Automated Investment Recording (AIR):
PwC implemented a mandatory program for PwC professionals who maintain a Checkpoint portfolio to help with recording and disposing of holdings through automated data feeds from many commonly used financial institutions. This removes the manual effort required by the PwC professional to update Checkpoint. AIR is also mandatory for immediate family members to hold eligible investments with an AIR participating financial institution. There are certain investment types or accounts (i.e. spousal employee benefit plans) that we cannot receive through an automatic feed, and these are required to be maintained manually in the PwC professional’s Checkpoint.
How can you access Checkpoint?
Have your PwC professional request third party access to Checkpoint for you (and your advisor). This function enables you to utilize the pre-clear and acquisition function in Checkpoint.
Immediate Family Checkpoint Checklist
Who is subject to compliance reviews?
PwC professionals required to maintain Checkpoint are subject to Personal Independence Compliance Testing (PICT). This process evaluates the completeness, accuracy and timeliness recording of their holdings in Checkpoint. Additionally, other financial arrangements and relationships are reviewed, alongside adherence to the firm’s mandatory AIR policy. This is a compulsory procedure, and non-compliance may result in sanctions, making accurate maintenance of Checkpoint important.
PwC professionals are also subject to periodic (bi-annually for partners and quarterly for managers) compliance confirmations where they are required to attest to the completeness and accuracy of their Checkpoint portfolios and compliance with the AIR policy.
How can you help?
By reading this, you’re already showing your support in helping our people maintain their personal independence - thank you.
Here are the next steps you can take to help your PwC professional stay on track with their personal independence:
1. Talk to your PwC professional regularly about your financial affairs. Communication is key.
2. Know what financial interests you hold by making a list. (e.g stocks, bonds, mutual funds, Exchange Traded Funds) They don’t need to know the value, just who the investment is with.
3. Before acquiring a new investment, ask your PwC professional to check if it's safe to acquire by pre-clearing it in Checkpoint. If you use an advisor, both you and your advisor can be granted third-party access to pre-clear investments in Checkpoint.
4. When acquiring a new, pre-cleared investment, please talk to your PwC professional as soon as possible, they will need to record your financial interests in Checkpoint within 14 days if maintained manually, otherwise the acquisition will automatically come through an AIR feed if the account is registered for AIR.
Note: When pre-clearing, use an appropriate security identifier for each of your investments to make it much easier to record; such as a CUSIP#, ISIN, fund code or ticker symbol.
AIR feed – ensure your eligible accounts are enrolled in AIR in your PwC professionals Checkpoint. You will still need to pre-clear to ensure it is permissible. The benefit of the automatic feed means you do not need to record or remove (if sold) manually.
Non-AIR accounts - (e.g. spouse benefit plan, non-Canadian accounts) cannot come through an AIR feed, so you will need to pre-clear and add as acquisition manually and remove (if sold) within 14 days.
5. When you make any changes to your financial affairs, continue to update your PwC professional.
Use this checklist to ensure you’re disclosing the right financial interests.
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- Talk to your PwC professional regularly about your financial planning discussions and decisions.
- Know all the financial investments you and your PwC professional have and make a list.
- Check with your PwC profesional to pre-clear or use third-party access to Checkpoint to pre-clear yourself.
- Record all your investments in Checkpoint within 14 days of acquisition.
- Update regularly to ensure any changes to your financial affairs are accurately reflected.
When might this change
Life events can change your Personal Independence responsibilities.
The roadmap to the right shows a few examples of what these could be for you and your PwC professional. If you’re unsure about how your recent life change may affect your shared Personal Independence responsibilities, ask your PwC professional to reach out to the Independence Office.
Personal Independence FAQs
