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Personal independence at PwC

A resource and overview of PwC’s personal independence requirements applicable to PwC partners, employees, third-party contractors and their immediate family members.

What is a financial arrangement and when is it permissible?

A financial arrangement is any of the arrangements described below. Permissible financial arrangements are those that are permitted by independence regulations and PwC policy.

Click on the financial arrangements below to learn more:

Securities

Examples of securities are stocks, bonds, mutual funds, money market funds, investment contracts, options such as puts and calls, other investments in a company and certain crypto tokens.

In certain circumstances, there are restrictions on owning securities in a company that is an audit client of PwC.

Checkpoint or the Compliance Resource Center can assess whether a particular security is permissible (see more below). Once permissibility is determined, securities must be recorded in Checkpoint within five business days of any transaction.

Credit cards

A credit card is a card issued by a bank which enables people to buy items without cash.

It’s important to know the bank issuing the credit card. In certain circumstances for credit cards issued by a PwC audit client, there may be a requirement to maintain a balance below a certain threshold and to make timely payments.

Checkpoint or the Compliance Resource Center can assess whether any independence-related requirements apply (see more below).

Insurance policies

Examples are automobile, boat, motorcycle, homeowner, second home, vacation home, title, renter, umbrella, accident, disability and life insurance policies.

In certain circumstances, there are restrictions on entering into a new or making changes to an existing insurance policy with a PwC audit client.

Checkpoint or the Compliance Resource Center can assess which insurance policies are permissible (see more below).

Bank accounts

Examples are checking, savings and money market accounts.

In certain circumstances, there are restrictions on using certain bank account features offered by a PwC audit client, such as overdraft protection or having a balance which exceeds Federal Deposit Insurance Corporation (FDIC) limits.

Checkpoint or the Compliance Resource Center can assess whether any independence-related restrictions apply (see more below).

Online payment tools

Examples are PayPal, Venmo, Twinspires.com, Poshmark seller and Etsy seller online payment tools.

In certain circumstances, there are restrictions on holding an overnight balance with certain online payment tools offered by a PwC audit client.

Checkpoint or the Compliance Resource Center can assess whether independence-related requirements apply (see more below).

Loans and mortgages

Examples are home, vacation and investment property mortgages and unsecured lines of credit.

In certain circumstances, there are restrictions on entering into new or making changes to an existing loan or mortgage with a PwC audit client. In addition, timely payments may be required.

Checkpoint or the Compliance Resource Center can assess which lenders are permissible and whether any other independence-related requirements apply (see more below).

Material leases

Any lease (other than automobile leases and leases from individuals) where the sum of the annual lease payments comprise 5% or more of the household’s gross annual income. The most common example is an apartment lease.

In certain circumstances, there are restrictions on entering into or making changes to an existing material lease with a PwC audit client.

Checkpoint or the Compliance Resource Center can assess which lessors are permissible (see more below).

Brokerage accounts

A brokerage account is an investment account that enables buying and selling of securities and a variety of other investments. Examples are Fidelity, Charles Schwab, Vanguard, Merrill Lynch, JP Morgan and Robinhood.

PwC has restrictions on which brokerage firms PwC partners, employees, third-party contractors and their immediate family members may maintain an account with.

Even if the brokerage firm is permissible, there may be restrictions on account features offered by the brokerage firm.  Examples of such features are automatic investing, money market sweep and margin options.

Checkpoint or the Compliance Resource Center can assess which brokerage firms are permissible and whether any other independence-related restrictions apply (see more below).

Employee benefit plan

An Employee Benefit Plan is a plan established by a company to provide retirement and savings benefits to its employees.

Any former employee benefit plan of a PwC partner, employee, third-party contractor or their immediate family members must be rolled over to an account with a permissible brokerage firm or into a current employee benefit plan. In addition, all securities held in a current employee benefit plan must be permissible.

Checkpoint or the Compliance Resource Center can assess which brokerage firms and securities are permissible (see more below). Once permissibility is determined, the securities held through the EBP must be recorded in Checkpoint within five business days of any transaction.

529 plans

A 529 plan is an investment account used to pay for education-related expenses.

Not all 529 plans are permissible.

Checkpoint or the Compliance Resource Center can assess which 529 plans are permissible. Once permissibility is determined, the 529 plan must be recorded in Checkpoint within five business days of investing in the plan.

What’s the best way to determine the permissibility of a financial arrangement?

It’s critical to confirm financial arrangements are permitted by independence regulations and PwC policy. Permissibility must be determined before entering into a new financial arrangement or making changes to an existing financial arrangement.

There are three options to determine the permissibility of a financial arrangement:

The Compliance Resource Center is a dedicated resource to help PwC partners, employees, third-party contractors and their immediate family members maintain personal independence, including assessing the permissibility of a financial arrangement. 

  • The Compliance Resource Center can be contacted by calling 1-877-PwC-HELP, option 5 (in the US), 1-813-351-6491 (outside the US) or 1-800-444-0103 (in Mexico).

  • PwC partners and their immediate family members, have a dedicated partner outreach liaison who they can contact directly to get assistance with any personal independence questions.

 

This proprietary tool informs PwC partners and employees (and their immediate family members and financial advisors) which financial arrangements are permissible and alerts them if a financial arrangement becomes impermissible. 

  • PwC partners and employees can also grant Checkpoint access to immediate family members and financial advisors, enabling them to pre-clear financial arrangements themselves.

PwC partners and employees can pre-clear financial arrangements using Checkpoint.

  • PwC partners and employees can also grant Checkpoint access to immediate family members and financial advisors, enabling them to pre-clear financial arrangements themselves.