A CPA's Retention of Client Records as a Means of Enforcing

A CPA's retention of client records as a means of enforcing payment of an overdue audit fee is an action that is:

A) Considered acceptable by the AICPA Code of Professional Conduct.
B) Ill advised since it would impair the CPA's independence with respect to the client.
C) Considered discreditable to the profession.
D) A violation of generally accepted auditing standards.