Section 80.125(c) provides that an independent CPA (or firm of CPAs) engaged by a refiner, importer or oxygenate blender may complete the attest engagement requirements with the assistance of internal auditors so long as such assistance is in accordance with the Statement on Standards for Attestation Engagements.

The Statement provides explicit professional standards for a CPA to be able to attest to the accuracy of records underlying an attestation engagement, including a standard pertaining to independence of mental attitude in performing an engagement. Accordingly, an independent CPA (or firm of CPAs) may be assisted by a company's internal auditors, but the independent CPA (or firm of CPAs) is ultimately responsible for complying with the Statement and for the representation made in the Attestation Reports required under § 80.130.

Section 80.125(a) requires that CPAs (or firms of CPAs) be independent of the company subject to the attestation engagement. However, company employees who are certified by the Institute of Internal Auditors as Certified Internal Auditors and who are also licensed CPAs, may perform attestation engagements.(7/1/94)

This question and answer was posted at Consolidated List of Reformulated Gasoline and Anti-Dumping Questions and Answers: July 1, 1994 through November 10, 1997 (PDF)(333 pp, 18.17 MB, EPA420-R-03-009, July 2003, About PDF)