An auditor is required to be independent. The American Institute of Certified Public Accountants (AICPA) requires that auditors followa four-step process or conceptual framework in which they (1) identify threats to independence. (2) evaluate the threats, (3) identify safeguards against the threats, and then (4) evaluate safeguards to ensure that they reduce threats to independence to an acceptable level. Use this process to reflect upon whether the Clifton auditors or Sam Card were independent. Refer to the AICPA's Code of Professional Conduct, Conceptual Framework for Independence ($1.210)22.23