APSCA Policy: Quarterly Reporting
4. Non-Compliant Reporting
4.1 Misreporting and Inaccurate Reporting: Member Firms are expected to ensure fully
accurate reporting. In cases of inaccurate reporting, APSCA may consult with the
Member Firm to allow for correction. However, where misreporting is found to be
intentional, systemic, or sufficiently serious, APSCA reserves the right to escalate
directly to the Disciplinary Board for Member Firms.
4.2 Corrective Measures: Failure to improve non-compliant reporting after consultation
with ASPCA will initiate the following corrective measures:
a. Letter of Engagement: This letter addresses identified non-compliance issues.
APSCA will provide the Member Firm with specific data points indicating targeted
areas of concern. This letter serves to guide the necessary changes and
improvements to meet APSCA’s Code.
b. Letter of Expectation: This letter will be issued to Member Firms requiring immediate
corrective action. APSCA will identify specific non-compliance concerns and may
suggest suspending social compliance audits in regions where the Member Firm has
demonstrated insufficient reporting. Further actions may be outlined as necessary to
reduce non-compliance under APSCA’s Code.
c. Letter of Expectation with Corrective Action Plan: In conjunction with issuing
the Letter of Expectation, the Member Firm will be responsible for developing a
formal Corrective Action Plan. Approval of this plan will be contingent upon it
being specifically tailored to address identified areas of non-compliance and
incorporating mandatory actions to facilitate effective change and improved
compliance.
Note: APSCA retains the discretion to determine the appropriate level of action, and the
Member Firm may be placed at any stage within this pathway.
4.3 Disciplinary Actions: If the Member Firm fails to demonstrate measurable
improvement in quarterly reporting following the corrective measures outlined above
or is found to be in intentional and/or systemic violation of the Code, APSCA reserves
the right to escalate the matter to the Disciplinary Board for Member Firms. All
disciplinary actions, including specific terms, conditions, and timelines for compliance,
will be communicated in writing to the Member Firm.
4.3.1 Provisional Member Firms may have additional or alternative corrective actions
at the direction of the Membership Team, which may impact their eligibility to
become a Full APSCA Member Firm.
a. Implementation of Enhanced Corrective Action Plans: The Disciplinary Board
may mandate the adoption of more stringent Corrective Action Plans tailored
to address specific areas of non-compliance.
b. Increased Reporting Requirements: Member Firms may be required to provide
enhanced and more frequent reports on their compliance efforts and progress.
APSCA Quarterly Reporting Policy - D-201
Document Name:
Version & Date:
Replaces:
Page 2 of 3
Author/Owner:
Authorized By:
Professional Conduct Team
APSCA Board of Directors
Version 1 - May 2025
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