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Common independence topics

Personal impact

Professionals who are employed by Deloitte are required to comply with our independence policies. These policies impact not only your own personal financial relationships, but also those of your spouse, spousal equivalent and dependents.

Newly hired professionals frequently need to take one or more of the following actions:

  • transfer investments to a new broker/financial advisor,
  • rollover former employer 401(k) plans,
  • cease outside employment at restricted entities (including part-time or weekend employment at retail stores), and
  • sell investments in restricted entities that are not permissible.

Below is only a partial list, but it represents common financial relationships and scenarios that are subject to reporting and/or ongoing monitoring and some may require divestiture to comply with independence policies if you are employed at Deloitte. If you have one or more of the financial relationships or situations described below and are unable or unwilling to divest or modify the scenario, you may want to contact Independence Compliance Onboarding by email (complianceonboarding@deloitte.com) before accepting employment with the Deloitte US Firms to discuss whether your assigned legal entity, role, or office location would require you to make changes.

Financial relationships

items marked with an asterisk (*) are common in India.

  • Depository accounts such as checking/savings accounts, certificates of deposit, salary accounts*, post office savings accounts* and cash balances associated with a health savings account (HSA)
  • Broker-dealer/securities accounts (including Demat accounts*, retirement (IRA), health savings accounts, and trust accounts).
  • Public and private securities including stocks/shares, bonds/debentures, mutual funds (including funds held in Systematic Investment Plan* – SIP), unit investment trusts, 401(k) investments, hedge funds, stock options, warrants
  • Digital assets (including cryptocurrencies, stable coins, and tokens of any kind) and digital wallet hosting services
  • Loans including mortgages/home loans, student loans, margin loans and secured/ unsecured (personal) loans
  • Insurance products including property & casualty (including homeowners’, renters’, and car/motorcycle insurance), life, health, disability, and long-term care insurance
  • Variable Insurance Policies or Annuities/Unit Linked Insurance Plans* (ULIP) – including all underlying public and private investments
  • College savings plan (529 Plans), established by you, your spouse, spousal equivalent or dependent
  • Trusts in which you, your spouse, spousal equivalent or dependent are named as a trustee or beneficiary
  • Inheritances
  • Credit cards with outstanding balances over $5,000
  • You, your spouse, spousal equivalent or dependent is named or acting as power of attorney or executor, administrator, or trustee of a trust or estate
  • Uniform gifts to minors (UGMA) and Uniform transfer to minors (UTMA) accounts

Business relationships

  • Partnerships
  • Joint investment (e.g., partnership interest, vacation home, boat, airplane, etc.)
  • Leasing space to/from a restricted entity (i.e., rent)
  • Ownership of a franchise or a personal business
  • Member of an investment club

Employment relationships

  • Severance or any other payments (bonus, 401(k) contribution, etc.) being received from previous employer
  • Vested pension with a previous employer
  • Former employer 401(k) plans or any other employee benefit plan, including stock option, profit sharing, and stock purchase plans (divestiture of prior employer benefit plans is required within 60 days of hire)
  • Spouse’s, spousal equivalent’s, or dependent’s former and/or current 401(k) plans or any other employee benefit plan (including pension, stock option, profit sharing, and stock purchase plans). Divestiture of prior employer benefit plans is required within 60 days of hire.
  • A spouse, spousal equivalent or dependent who is employed in an accounting, financial reporting or other significant role at a company
  • Your current or previous employer is a restricted entity
  • You or your spouse, spousal equivalent, or dependent is an officer or member of a board of directors or audit committee (whether for pay or not)
  • Community activities/community leadership positions
  • Non-Deloitte employment or independent consulting services, including but not limited to professor/instructor roles, part-time employment (e.g., retail store, self-employment, family business, professional service, any other type of paid position), and providing independent contractor services (e.g., sales- or commissions-based activities)


Also consider certain relationships that you are aware of pertaining to your Close Family Members. “Close Family Members” includes your parents, step-parents, non-dependent children and siblings. Note that unlike your spouse, spousal equivalent and dependents, when it comes to Close Family Members, if you are not aware of these situations, you are not required to ask.

Consider contacting Independence Compliance Onboarding if you are aware of a Close Family Member who has one of the following situations: a financial interest in a company that is material to his/her net worth or employment in an accounting, financial reporting or other significant role at a company.


  • Deloitte US Firms–Includes the following: Deloitte LLP, Deloitte & Touche LLP, Deloitte Tax LLP, Deloitte Financial Advisory Services LLP, Deloitte Consulting LLP, Deloitte Services LP, and their affiliates
  • Independence–Integrity, professional skepticism, intellectual honesty, objectivity, freedom from conflicts of interest both in fact and appearance
  • Restricted entity–Any attest (audit) client and its affiliates including non–client affiliates of the attest client
  • Spousal equivalent–Relationship is deemed to exist in any of the following case:
    • A civil union in which the applicable law does not define the parties as spouses.
    • A domestic partnership registered with a governmental body.
    • A domestic partnership has been declared by the parties for joint coverage under an employer health and welfare benefit plan.
    • The parties hold themselves out as married.

Absent the specific relationships above, a Spousal Equivalent relationship may still exist based on individual facts and circumstances. Professionals are required to use professional judgment in determining whether a Spousal Equivalent relationship is deemed to exist. Although no one factor will necessarily indicate the existence of a Spousal Equivalent relationship, factors to be considered in making such determinations include the following:

  • Providing or receiving coverage or benefits under each other’s medical insurance or other employee benefit plans
  • Having co–ownership of real property in which both parties continually reside
  • Being co–debtors on a mortgage on the real property in which both parties continually reside
  • Continuing to reside together in the same residence and having either natural or adopted children
  • Having financial dependency on each other, including commingling of investment and financial resources
  • Having joint responsibility for each other’s welfare and financial obligations
  • Cohabitating and being engaged to be married with a marriage scheduled in the foreseeable future
  • Having a committed relationship that is ongoing and expected to continue indefinitely similar to that of a married couple, but having either chosen not to marry or cannot legally marry

Resources upon joining the Deloitte US Firms

Deloitte Entity Search and Compliance (DESC) System–An internal system that, among other things, contains information regarding entities that are restricted for independence purposes. This information will assist you in determining whether or not acquiring or having certain financial relationships would create a potential independence issue.

Tracking & Trading System–An internal tool to help you monitor your compliance with independence requirements related to certain personal investments and financial relationships. You report the names of entities with which you, your spouse or spousal equivalent, and dependents have a financial relationship. The system then monitors these entities against the restricted entity list and informs you if there is a potential exception or conflict.

Broker Data Import Program (BDIP)–A feature of the Tracking & Trading System that allows the professional to receive automatic downloads of their financial holdings from their authorized brokerage accounts. This minimizes much of the administrative nature of maintaining Tracking & Trading and ensures brokerage account transactions are recorded timely and completely.

  • Enrollment in BDIP, using only the approved, participating brokers, is mandatory for those required to maintain a Tracking & Trading System portfolio. This is not mandatory for brokerage/Demat accounts held in India.
  • For more information about this requirement, candidates should discuss the Broker Data Import Program with Independence Compliance Onboarding team by email (complianceonboarding@deloitte.com).

Representation on Independence, Ethics and Compliance–A personal declaration or statement regarding the facts and circumstances associated with the various financial or other relationships you, your spouse or spousal equivalent, and certain family members may have that directly impact the ability of the Deloitte US Firms to conduct business.

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