I was quoted last week in an article by Amanda Iacone of Bloomberg BNA about recent research that suggests the one-year cooling off period may not be long enough to mitigate independence concerns. (I blogged about this study on February 9th.) When asked what firms can do to counter the possible effects of the familiarity threat the researchers found, I raised the AICPA independence rules, which require firms to apply certain safeguards when a former partner or staff joins an attest client in a "key position" (e.g. CFO), especially if the transition from firm to client takes place within a one-year period. Specifically, the firm should evaluate whether the audit plan and the team's experience, stature and professional skepticism effectively mitigate independence concerns caused by the ex-auditor's familiarity with the audit plan, and/or his or her stature and possible influence on the remaining audit team members. And I do believe that firms who diligently apply the AICPA safeguards (for specifics, see 1.279.020), would effectively address any possible threats to their independence.