An accountant who provides any of the listed non-audit services to the insurer contemporaneously with the audit is not qualified: bookkeeping or other work on the accounting records or financial statements; financial information systems design and implementation; appraisals, valuations, fairness opinions and reports on contributions in kind; actuarial advisory work that fixes amounts recorded in the statements (helping the insurer understand methods and assumptions is allowed only where that help will not itself be audited, and the accountant's actuary may opine on reserves only if neither performed management functions, the insurer has competent staff or a third-party actuary responsible for the estimate, and the test of reasonableness follows management's determination); internal audit outsourcing; management functions or human resources; broker-dealer, adviser or investment banking work; legal or expert work with no connection to the audit; and anything else the commissioner designates. The principles behind the list are that the accountant cannot act as management, audit its own work or advocate for the insurer. Insurers under one hundred million dollars of direct written and assumed premium may apply for an exemption on hardship grounds.
The graph holds this control, the 0 it maps to, and the evidence behind each claim, over MCP and REST.