party because it is required to communicate about non-compliance with laws and regulations (NOCLAR) committed by a client to the appropriate regulator; - The firm may consider the network firm as a

position at the client? (d)  If not a partner – were they a former member of the engagement team within the last two years and have they joined the client as a director or in a key management position? 3

establishing a specific time period to make that evaluation? If yes, do the conditions include: • significant changes in the client (such as ownership, management, nature of business or financial position

or part- time auditors and individuals in the service delivery center) If yes, please describe. 2 How does the firm determine staffing requirements and minimum qualifications for each position? (full