An Examination of the U.S. Public Accounting Profession’s Public Interest Discourse and Actions in Federal Policy Making


Participation in the political process by the United States public accounting profession often blurs the role of the profession as advocates for the public interest with its role as advocates for its own private interests. In this study, we draw from prior theoretical and empirical work to investigate recent federal political activities of the public accounting profession to shed light on these sometimes contradictory roles. In particular, we investigate ten contemporary regulatory issues of interest to the AICPA. We analyze 36 AICPA legislative advocacy letters related to these issues that were provided to federal policy makers. In addition, we analyze the public accounting profession’s federal lobbying reports that were submitted during this same time period. The analysis allows us to assess the public interest discourse present in the AICPA legislative letters as well as the extent of political action taken by the profession related to these issues based on the profession’s lobbying efforts. Our analyses (1) demonstrate that the profession’s discourse and actions often reflect both public and private interest motivations, (2) allow us to categorize the profession’s advocacy efforts as arising from specific motivations, and (3) show that the profession’s public interest arguments used to advocate for their policy positions change depending upon the specific legislative issue being considered.

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  1. 1.

    Although beyond the scope of our study, it is important to note that other professions are also involved in federal policy making. For example, during the 2010–2012 election cycle, the American Medical Association incurred lobbying expenses of $21,500,000 and made PAC contributions of $3,064,664. The American Bar Association incurred lobbying expenses of $2,005,000 and made no PAC contributions.

  2. 2.

    Early work by Puro (1984) contrasted economic regulation and agency perspectives to explain audit firm lobbying before the Financial Accounting Standards Board without regard for potential normative public interest rationale for their advocacy choices. Later work by Kothari et al. (2010) directly addresses competing theories of regulation, explicating how public interest, capture, and ideological theories might explain accounting regulation over GAAP. Kothari et al. (2010) dismissed the public interest theory because they saw little prior empirical support for the presence of the theory’s requirement of “benevolent and omniscient policy makers” (p. 251) who would guide policy without regard for their own private interests. Regulatory capture theory, therefore, may be viewed as similar to the abolitionist perspective, while the ideological theory is more in line with the process perspective.

  3. 3.

    There are 24 unique issues reflected on the AICPA advocacy webpage as of December 2014. Nine of these issues are included in our analysis. We add one issue not reflected on the AICPA advocacy webpage (mandatory audit firm rotation), as it was a unique issue listed on the CAQ advocacy webpage. We exclude the other 15 AICPA-listed issues due to lack of data, meaning either: (1) the AICPA or CAQ did not write any legislative letters related to the issue, and/or (2) there is no bill associated with the issue, thus no lobbying reports. Both factors prevent us from assessing the public discourse and lobbying actions related to those issues. An example of such an issue is “financial literacy and education,” which the AICPA regularly promotes, but no legislative letters have been written or bills lobbied related to this issue.

  4. 4.

    We retrieve all lobbying data from the Center for Responsive Politics ( The data are compiled using lobbying disclosure reports filed with the Secretary of the Senate’s Office of Public Records and posted on its website. Lobbying firms are required to submit a quarterly report for each client from which it receives at least $3,000 in lobbying income per quarter. Likewise, organizations that spend more than $12,500 quarterly on in-house lobbyists must report all lobbying-related expenditures per quarter. Within these lobbying reports, the filer indicates one or more general issue areas and the related bills lobbied in the quarter. The dollar amount spent lobbying, however, is not itemized based on issues and/or bills. Instead, the filer simply reports a lump sum dollar amount for the quarter.

  5. 5.

    The three bills are titled, “Mobile Workforce State Income Tax Simplification Act of 2013” (H.R. 1129), “Mobile Workforce State Income Tax Simplification Act of 2012” (H.R. 1864), and “Mobile Workforce State Income Tax Fairness and Simplification Act of 2007” (H.R. 3359).

  6. 6.

    We downplay process theories of public interest in our analysis as this speaks more to the “process by which conflicts [between special interest groups] are transformed” (p. 1085) which is not the focus of our paper.

  7. 7.

    We present examples of sentences coded under each public interest conception in Exhibit 3.

  8. 8.

    We exclude a small number of large bills (i.e., bills that garnered the attention of 200 or more unique organizations, such as Dodd–Frank) from this analysis because such bills are typically associated with two or more of the regulatory issues of interest in this study, making it difficult to link the lobbying for that bill to one particular issue. For example, of the 54 accounting profession lobbying reports that list Dodd–Frank in the lobbying activity, it is difficult to determine the extent to which those lobbying efforts related to FASB independence, municipal advisor definition, 404(b), or XBRL, all of which are issues discussed in the formation of Dodd–Frank.

  9. 9.

    The vast majority of lobbying by the public accounting profession stems from the AICPA and Big 4 firms. In an attempt to capture other accounting profession lobbying activities, we examine the lobbying efforts of mid-tier accounting firms. Of those, only Grant Thornton lobbied on some of the issues examined in this study. Other mid-tier firms either do not lobby or do not have lobbying reports related to the issues we examine. We note that Grant Thornton represents such a small percentage of the lobbying related to the issues in this study, that our results in Exhibit 4 remain unchanged with the inclusion or exclusion of this firm.

  10. 10.

    We realize that lobbying expenditures associated with each bill is a finer measure of an organization’s interest in a particular bill (as opposed to a count of reports). Lobbying reports, however, do not currently itemize lobbying costs based on issue and/or bill. At this point, one dollar amount is provided per report, which covers all lobbying activities.

  11. 11.

    Bills often span several years, in which lobbying efforts are made surrounding each step the bill takes in the legislative process (i.e., House vote, Senate vote, reconciliation of differences, President signature). The year in which we assess the public accounting profession’s involvement is the year of the most lobbying activity surrounding the bill based on the number of unique organizations lobbying the bill and the accounting profession’s activity for the particular bill.

  12. 12.

    We acknowledge that under both of our public interest and private interest classification schemes, many of the regulatory issues may fall into one or more categories. In those situations, we classify the regulatory issue into the category that it most closely aligns with, fully acknowledging that a single issue may have aspects that fall into two or more categories of public or private interest.


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We thank Vishal Baloria, Mike Garvey, Sally Gunz, Linda Thorne, Stephen Zeff, and participants at the University of Waterloo 2nd Biennial Symposium on Accounting Ethics, the 2015 American Accounting Association Conference of the Public Interest Section, and the 2015 Alternative Accountants Conference for helpful comments and suggestions.

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Correspondence to Robin W. Roberts.


Appendix 1

Exhibit 6 Total political spending by organization by election cycle

Appendix 2

Exhibit 7 Number of reports mentioning specific lobbying issues by organization (2008–2012)

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Baudot, L., Roberts, R.W. & Wallace, D.M. An Examination of the U.S. Public Accounting Profession’s Public Interest Discourse and Actions in Federal Policy Making. J Bus Ethics 142, 203–220 (2017).

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  • Lobbying
  • Politics
  • Accounting
  • Professionalism