Personal Independence FAQs

At PwC, we provide assurance services. Our name adds credibility to information prepared by our clients. For an audit or assurance report to have value, the users of the financial statements must believe that PwC, as the audit firm, has not been influenced by any relationships or situations that undermine our objectivity. Independence is about the different types of relationships the firm and our people are permitted to have with audit and assurance clients of the firm.

Our independence policies and procedures are put in place in order to protect our firm, our clients and our people. Being independent allows PwC partners and staff to make decisions about our work and our clients unencumbered by personal interests. It’s what is expected of us by our clients, our regulators and the marketplace.

Immediate family members include a PwC professional's spouse or spousal equivalent, all dependent children (including stepchildren), and others who receive substantial financial support from the PwC professional and over whom significant influence is exercised. A spousal equivalent is a cohabitant occupying a relationship generally equivalent to that of a spouse.

Partners and managerial level practice staff are required to maintain an inventory of financial interests for themselves and immediate family members in the firm's Checkpoint portfolio system. This includes investments such as stocks, bonds, mutual funds, and some cryptocurrencies. Refer to the Immediate Family Checkpoint Checklist.

PwC implemented a mandatory program, Automated Investment Recording (AIR) for managers and above 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 that we cannot receive through an automatic feed, and these are required to be maintained manually in the PwC professional’s Checkpoint.

Financial arrangements such as life insurance policies with a savings element, Registered Retirement Savings Plans (RRSPs), current and former employer pension plans, Registered Education Savings Plans (RESPs), Tax-Free Savings Accounts (TFSAs), stock options or incentive compensation plans, cryptocurrencies, and non-fungible tokens (NFTs) should be considered for independence.

Immediate family members should discuss their financial decisions with the PwC professional to assess independence restrictions. Before making new investments, they should pre-clear the transactions in Checkpoint. All completed securities transactions and fully disposed securities should be recorded/removed in Checkpoint within 14 calendar days. Don’t forget the use of the mandatory AIR program that can help reduce the manual recording of holdings for eligible accounts with participating financial institutions that are enrolled in AIR in Checkpoint.

Life events such as divorce, separation, marriage, new job for a spouse, new cohabitation, or having children can lead to additional requirements for personal independence. It is important to talk to your PwC professional to understand the impact of these life events on their independence.

Immediate family members should make independence considerations part of their regular financial planning discussions. They should review statements and notifications from brokers or financial institutions to ensure there have been no changes to their portfolio that should have been recorded in Checkpoint. They should also ensure that their financial advisor or investment manager does not purchase or trade securities on their behalf without pre-clearing in Checkpoint and only acquiring permissible holdings.

Independence policy and application guidance is available on PwC’s internal Independence Office Daily Hub page that your PwC professional can access. There is also a help desk function within the Independence Office to support Checkpoint compliance and answer other questions. Immediate family members can direct any questions to the Independence Office at ca_independence_office_canada@pwc.com

Review statements and notifications from brokers or financial institutions to ensure there have been no changes to the portfolio that should have been recorded in Checkpoint. Pay particular attention to communications regarding account or investment option changes. Whenever there is a change to investments, even if initiated by someone other than PwC professional or your immediate family member, this change must be pre-cleared and recorded in Checkpoint.

An investment manager or robo-advisor account may be making investment decisions on a person’s behalf; however, this does not remove the requirement for compliance with firm independence policies. PwC professional remains primarily responsible for compliance, including assessing and pre-clearing investments prior to acquisition, and maintaining an accurate portfolio. Discretionary or managed accounts should be avoided unless they can be structured in a way that ensures compliance with policies.
 

Job changes of an immediate family member will likely bring about independence considerations associated with new employers or positions. Pay particular attention to any Employee Benefit Plans (EBPs) such as pension plans or stock options with investment options of new or former employers, including your own former employers, where applicable. Discuss new job changes with your PwC professional to ensure there are no independence concerns.

Relationships, such as beneficiary ownerships, trusts, and estates, partnerships, or powers of attorney, can be complex and there could be independence considerations. Discuss these with your PwC professional if you have any questions or need assistance navigating the impact of these life events on your PwC professional’s independence.

The AIR program is an automated data feed from many commonly used financial institutions to the Checkpoint portfolio system. AIR automatically reconciles accounts for registered financial institutions and users. It is mandatory for managers and above who have a Checkpoint portfolio (including for their immediate family members) to have all eligible financial interests held in accounts with financial institutions onboarded to the program. AIR removes the manual effort required by the PwC professional to update Checkpoint. 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.

Immediate family members and advisors can gain third party access to your PwC professional’s Checkpoint portfolio. Access can be restricted to specific folders and provided to multiple third-party users. This feature allows authorized external users (e.g., your spouse, broker, dependent) to pre-clear, add, and dispose of investments in Checkpoint. This can help you manage your PwC professional's compliance obligations and reduce the violations caused by failing to pre-clear investments and record acquisitions and disposals within 14 days.