Conflict-of-interest checks for CPAs offering CAM audit services
CPA firms are natural CAM audit partners because they already understand reconciliations, expense classifications, and client advisory delivery. The conflict problem is that commercial real estate relationships are connected. The tenant asking for help may lease from a landlord the firm already serves. The property manager may be a bookkeeping client. A partner in the firm may own an interest in the center. A referral fee may be involved. This check should sit beside the firm's unauthorized-practice-of-law controls, because both determine whether the firm can safely accept and communicate the engagement.
A conflict check turns those possibilities into a documented intake control. It protects objectivity, preserves client confidentiality, and gives the engagement partner a clear answer before the firm accepts the work.
This guide is general professional-practice information, not legal or ethics advice. CPA firms should confirm application with their state board, insurer, and counsel.
The conflict map to run before acceptance
Run the check before the proposal goes out. The firm should identify:
The tenant client. Confirm whether the tenant is already a firm client, a prospective client, or a referred party with no existing engagement.
The landlord and property owner. Many leases name one entity while invoices come from a property manager or affiliated ownership vehicle. Check the lease, reconciliation statement, W-9, and payment instructions.
The property manager. A firm that provides bookkeeping, tax, payroll, or advisory services to the manager may have confidential information that cannot be used in the tenant engagement.
Known related parties. Check owners, funds, franchise affiliates, management companies, and entities named in lease amendments.
Firm financial interests. Ask whether firm owners or staff have an investment interest in the property, landlord, tenant, or referral source.
Referral-fee relationships. Document whether a commission, referral fee, revenue share, or reciprocal referral arrangement exists.
The highest-risk scenarios
The firm audits or reviews the landlord. A tenant-side CAM audit challenges amounts billed by the landlord. If the landlord is an attest client, the firm should assume the engagement needs ethics review before acceptance. Independence, objectivity, and confidential-information risks can all be present.
The firm prepares tax returns for both sides. Tax-only relationships may be manageable, but the firm still needs to evaluate whether serving the tenant against the landlord creates a threat to objectivity or exposes confidential client information.
The firm advised on the lease or reconciliation process. If the firm helped the landlord design the CAM reconciliation process, then later reviewing that same process for a tenant creates a self-review risk.
The engagement depends on nonpublic landlord information. The CAM audit should use documents provided by the tenant for the tenant engagement. Information obtained from a landlord client cannot be used unless disclosure is authorized and professionally appropriate.
Consent and documentation
When a conflict is permitted and manageable, document informed consent before work begins. The file should show:
- The parties checked.
- The relationship that created the potential conflict.
- The safeguards applied, such as separate teams, restricted file access, or independent partner review.
- The disclosure made to the affected client or clients.
- Written consent, when required.
- The decision memo explaining why the firm accepted or declined the engagement.
If the firm cannot disclose enough information for the client to provide informed consent without revealing another client's confidential information, the safer answer is to decline.
Referral fees and partner economics
The AICPA professional-responsibility materials emphasize disclosure of commission and referral-fee arrangements. For CAM audit partners, the practical rule is simple: if the firm receives compensation because the client purchases a scan, a credit pack, or a related service, disclose that arrangement in writing before the client buys.
The disclosure should state who pays the fee, how the fee is calculated, whether the client's price is affected, and whether the firm is providing the CAM audit service directly or referring the client to CAMAudit.
Source Notes
- AICPA Code of Professional Conduct, ET Section 1.110, Conflicts of Interest.
- AICPA Code of Professional Conduct, ET Section 1.700, Confidential Information.
- AICPA and CIMA, Professional Responsibilities resource, including conflict, confidentiality, and referral-fee disclosure expectations.