The American Institute of Certified Public Accountants (AICPA) is presently considering a proposal to revise the enforcement system of the Code of Professional Ethics from the current complaint-based mechanism to a system based on reviews of practitioners and their work. Inherent within the proposal is the conclusion that the existing enforcement provisions, based on complaints about violations, are not adequate.

Complaints about ethics violations can originate from practically anyone although two of the primary initiators of violation complaints are Certified Public Accountants (CPAs) and their clients. CPAs, however, may have limited opportunities to observe violations committed by colleagues. Clients, on the other hand, may be in a prime position to detect departures from the ethics code but may have no incentive to report violations committed by their CPAs; e.g., a violation may benefit the client.

A survey of these two groups (CPAs and clients) indicated that while both groups are familiar with the code and believe that the rules of conduct are appropriate, clients do not tend to report violations and CPAs, on average, indicated that they would report observed violations slightly more than one-half the time. These findings suggest that an enforcement system based solely on the complaints of CPAs and clients cannot be effective.