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Since the activities described as expert services in the proposed rule would , for the most part , be considered legal services under German law , it should be stressed , again , from the German perspective , those providing such services may not identify themselves with the interests of their clients . In addition , the proposed rules would require issuers to provide advance notice to their directors and executive officers and the Commission of the imposition of a pension plan blackout period . While we anticipate that accounting firms , when possible , would stagger the rotation of partners to provide a continuity of knowledge about the company , we believe the five-year period in the proposed rule would assure a complete turnover of personnel every five years . In addition , the proposed rules would require companies to regularly review and evaluate their procedures that enable them to fulfill their periodic reporting obligations . Baruch Fellner , an attorney with Gibson , Dunn & Crutcher LLP in Washington , D.C ., who has represented businesses in OSHA rulemakings , said the proposed rule would lead to further debate over how often replacements are issued and disciplinary measures for missing equipment - - - issues best left to the human resources department or the collective bargaining process . Accordingly , the proposed rule would require a flammability exposure analysis of the auxiliary fuel tank design , an impact assessment to determine any adverse impact its design may have on the original or modified type design , and development of a flammability impact mitigation means ( FIMM ) to address adverse changes in flammability exposure . Thus , the proposed rules would apply to foreign and U.S. accounting firms and legal practices equally , minimizing and possibly eliminating the instances where legal services are provided by the auditor to an audit client . With respect to determining which partners , principals and shareholders should be included , the proposed rules would go beyond the minimum specified by the Act. As part of the settlement of the ACLU ’ s case , the government agreed for the first time to release a copy of the rules of the court from 2000 , which the proposed rules would replace .