November 16, 2018

Audits

EY Remains the Most Audit-y of the Public Company Auditors

Congrats to EY for once again having more public company audit clients than any other Big 4 firm. Of the 6,167 public registrants in the United States, EY audits 921 of them, or 14.9%, according to Audit Analytics’ Who Audits Public Companies – 2018 Edition. PwC is next with 658 public company audits, or 10.7%; […]

department-of-defense-audit

The Defense Logistics Agency Be Like, “Accounting? What’s Accounting?”

Occasionally I will see something charged on my credit card that I don’t remember. I rack my brain. Sometimes I start to think maybe someone’s stolen my card number. But, more often than not is a charge from an obscure parking meter or something similarly mysterious that I didn’t commit to memory. The credit card […]

audit dod department of defense

Ready or Not: Auditors Descend on Department of Defense

It’s not as cool as a multi-ship C-17 formation dropping paratroopers as a part of a training exercise (like the one that everyone thought was a UFO on Saturday night). But, our profession’s only semi-equivalent — 2,400 red-pen wielding auditors — will infiltrate the Department of Defense (DoD) this month to kick butt and take […]

Fake Occupants Caused Some Some Problems in Grant Thornton’s Audit of Assisted Living Concepts

The SEC announced a settlement with Grant Thornton and two partners today over some bad audits that went down in America's Dairyland. The firm will pay $3 million in fines, plus forfeit $1.5 million in audit fees with interest. The partners, Melissa Koeppel and Jeffrey Robinson agreed to a $10k fine and a 5-year ban and $2.5k and 2-year ban, respectively.

UK Auditor Regulator Stops Short of Calling Grant Thornton Audits ‘God-Awful’

The PCAOB inspection report for Grant Thornton, while worse in susbtance, doesn't quite express the feelings of a regulator who expects a little more.  A report from the UK accountancy watchdog said it was “disappointed” to find that five of the eight Grant Thornton audits it reviewed required either improvements or significant improvements, a blow […]

Whistleblower Confirms BP Gripes of McGladrey’s ‘Astronomical’ Fee for Audit of Deepwater Payments

Back in October, we learned that BP was upset with McGladrey over the firm's audit of BP's 2010 Deepwater Horizon spill victim compensation program. The problem? Money, of course: With audit costs allegedly running nearly tenfold over budget and no audit in sight, BP last week asked a federal court to force the claims administrator […]

DoD Figured the Navy Didn’t Need a Flashy Name on Its Audit Opinion

In press releases you didn't read this month news, the Department of Defense announced earlier this month that it had awarded contracts to audit the Army, Air Force, and Navy. Let's see who the lucky winners of that particular cluck mission are: The Department of Defense has awarded contracts to independent public accounting firms to […]

McGladrey’s PCAOB Inspection Report Is the Least Embarrassing Thing About McGladrey

We were too busy yesterday making AS5 jokes about KPMG to talk about McGladrey's 2013 PCAOB inspection report, which was released at the same time. McGladrey is used to warming the bench over Big 4 firms so we figured they could wait for us to get around to it. The news is pretty good, at […]

KPMG’s Re-Audit of Ventas Teaches Us Boning Doesn’t Necessarily Ruin an Audit

Colin buried this in ANR this morning: Health-care real-estate investment trust Ventas Inc. ( VTR ) said a re-audit didn't result in any changes to its financial statements. KPMG LLP audited Ventas's 2012 and 2013 figures after Ventas said in July that it dismissed Ernst & Young "as a result of an inappropriate personal relationship" […]

Let’s Use the Center for Audit Quality’s New Auditor Judgment Tool to Decide on Lunch

The CAQ released a new Professional Judgment Resource today, "designed to provide auditors with an example of a decision-making process to facilitate important auditing and accounting judgments in a professionally skeptical manner." Get excited, people, this is awesome stuff: The Resource is aimed at assisting auditors who are responding to judgment challenges arising from the […]

The Name of EY’s New Audit Tool Implies Audits Belong in the Louvre

As a creative, right-brained type myself, I realized very early on in my time in CPA review that the CPA exam was less a test of knowledge and more a test of a person's left brain to process and spit out information exactly as it was put in. In other words, the exam weeds out […]

Grant Thornton Fails to Take Up the PCAOB’s Offer to Get Better at Auditing

The good news for Grant Thornton is that they managed to take remedial actions related to their 2010 inspection report and addressed criticisms to the satisfaction of the PCAOB. Cheers!  The bad news is that the same cannot be said for their 2008 and 2009 reports. The quality control remediation process is basically a way […]

Not Auditing Is Twice as Effective as Auditing at Catching Fraud

Today, we have an interesting ACFE report that not looking for fraud is more than twice as effective as external audits at detecting internal fraud. From CFO.com: In the recent past, the Association of Certified Fraud Examiners has described where companies should concentrate their monitoring for employee fraud. In finance departments, for example, a majority […]

Some Companies Unsure About This New COSO Internal Control Framework

Some dates are not set in stone, like the day of the week I decide to clean the cat fountain or change my sheets. Others, like the day I need to pay my rent and the fiscal year-end on or after December 15, 2014 are not so variable. When it comes to COSO's new 2013 […]

CohnReznick Is Probably Better at Audits Than You, Per PCAOB Inspection Report

Yesterday, we shared McGladrey's not-all-that-bad inspection report results. Now, it's time to crown a world champion audit firm… CohnReznick! The words every audit firm wants to hear from the PCAOB: The inspection procedures included a review of aspects of the Firm's auditing of financial statements of 11 issuers. This review did not identify any audit […]

If China Won’t Play, the PCAOB Will Find Someone Else to Play With

Keep holding out, China, the PCAOB don't need to check your stinkin' work anyway: Washington, DC, March 31, 2014 — The Public Company Accounting Oversight Board today announced that it has entered into a cooperative agreement with the Supervisory Board of Public Accountants (RN) of Sweden relating to the oversight of audit firms subject to […]

One Guy at the PCAOB Thinks the PCAOB Should Consider Its Language

Aha! Pointy-headed professors aren't the only ones who think the PCAOB's use of the term "audit failure" is totally dramatic and possibly unnecessary. From the JofA: The PCAOB’s use of the term “audit failure” in its inspection reports of audit firms appears to have caused confusion and misunderstanding about the severity of inspection findings among […]

Fraudsters Get High on Fraud, Auditors Get High on… Not Committing Fraud?

This groundbreaking idea brought to you by the AICPA Insights blog: According to a recent blog entry on the New York Times’ website, researchers have found that people who cheated, and got away with it, experienced a thrill, self-satisfaction and a sense of superiority. While that sensation was not as strong as the high that […]

The SEC Bans Big 4 Member Firms in China For Failing to Show Their Work

There's a storm a-brewin' in China and isn't a "fake" sun going viral. In a massive 112-page opinion, SEC judge Cameron Elliot has brought the hammer down on Chinese units of Big 4 firms, ruling that these units should be barred from auditing U.S.-traded companies for six months. The ruling comes after these member firms […]

Let’s Congratulate Grant Thornton For Its Dynamic and Record-Breaking Audit Failure Rate

Colin put this in ANR this morning but it's the kind of thing that deserves a post of its own just to make sure you don't miss it and mock appropriately: The Public Company Accounting Oversight Board gave a failing grade to Grant Thornton on 65 percent of audits inspected in 2012, the highest failure […]

EY Still Planning to Settle With Lehman Investors, Also Still in Denial

Back in October, it was reported that EY planned to settle with Lehman Bros investors, subject to court approval (EY's denial notwithstanding): Ernst & Young LLP has agreed to pay $99 million to settle investor class-action allegations that it turned a blind eye when its audit client Lehman Brothers Holdings Inc. misled investors before the […]

Former Madoff CFO Claims Madoff Faked Documents For KPMG Audit Using a Refrigerator

This just in and developing, we will keep you posted: BREAKING: Former Madoff CFO says Madoff Securities forged documents during KPMG audit and cooled newly-printed documents in refrigerator. — CNBC (@CNBC) December 2, 2013

Oregon Man’s Encounter with IRS Agent Oddly Similar to the Plot of a Bad Porno Movie

Today in bizarre sexual encounters with government employees news, a Fall Creek, Oregon man has filed a lawsuit against an IRS agent for "coerc[ing] him into having sex with her after suggesting that the liaison could keep him out of tax trouble." Dora Abrahamson claims to have known Vincent Burroughs when she called him to inform that […]

ParenteBeard’s “Audit” of Santa Is as Reliable as Santa Himself

ParenteBeard, the 23rd largest CPA firm on the whole damn planet, issued the following press release earlier this month. This holiday season, ParenteBeard, a top 25 U.S. accounting firm, is helping to balance the books of what would be the largest nonprofit in the world: Santa, Inc. […] ParenteBeard began its audit of Santa, Inc. […]

Anecdotal, Unverifiable Evidence Confirms That Broker-Dealer Audits Are as Bad as You Thought They Were

Digging through the mailbag, I found this little gem: I'm not surprised broker dealer audits are bad. I used to be on a high profile one and let me tell you I spent so much time to trying to understand the business. At the end of the day, you get a general idea as to the operations BUT […]

Mitt Romney Is Pleased with PwC’s Tax Services

In an interview with ABC News yesterday, Willard shared a few new tidbits about his life as a taxpayer: 1) He's not sure if he's ever payed less than a 13.9 effective tax rate 2) he's had the distinct pleasure of being audited by the IRS and 3) the crack squad in PwC's Boston* office […]

Deloitte Informs Indiana Officials That When You Let $526 Million Go Missing That, Yeah, It Can Take Awhile to Find It

Maybe you're not aware of this, but the state of Indiana lost track of $320 million in corporate taxes. Yep! They know that "state workers did not properly enter changes in the state's tax collection system" but why it took them four years to discover the problem is anybody's guess. Oh, and they also owe […]

The Big 4 Greeters Aren’t Necessary, Thank You

“We don’t want the Wal-Mart audit.”

~ The aforementioned Lynn Turner, cringes at the thought of low prices.

It’s Not Impossible To Make Money on Small Audits

The following post is republished from AccountingWEB, a source of accounting news, information, tips, tools, resources and insight–everything you need to help you prosper and enjoy the accounting profession.

Most small firm practitioners can offer lots of answers as to why it is difficult to profit from small audits. Ever-changing professional standards, increasing quality control requirements, using standard “one-size-fits-all” audit documentation and increasing legal liability are a few of the common answers. The problem is that knowing the answer doesn’t solve the problem!

Maybe we need to change the question to solve the problem. A better question may be, “What changes do we need to make in our audit practices to profit from small audits?” Answer this question correctly and we solve a major problem!

Here are changes in audit practices some smaller CPA firms are considering:


• Developing the technical and leadership abilities of engagement leaders is at the top of the list. Recognizing this takes time and money, small firms are making increasing investments in training and consultations to expand the knowledge resource base of their leaders and the firm. Making sure leaders are technically current in all professional standards affecting auditing engagements is a first step. Teaching leaders to pass their knowledge on to all assistants is the second.

• Designing firm policies and procedures within existing professional standards that provide reasonable assurance audited financial statements are not misstated. While we’d like to achieve absolute assurance the financial statements are not misstated, we have to assume some risk they may contain misstatements. In short, we have to give up some of our traditional approaches to audits in exchange for uniquely tailored audit strategies designed to gather the minimum amount of evidence necessary to verify relevant financial statement assertions. Gathering the minimum required evidence in the most efficient ways results in maximum profits!

• Creating proprietary audit documentation packages by eliminating or modifying documentation purchased from major publishers. Extensive audit documentation is not a substitute for the knowledge of staff personnel! We cannot afford to complete practice aids and other documentation containing everything we need to know on every engagement, particularly on small audits. Many small firms are realizing they can modify their quality control documents to permit engagement leaders to tailor documentation on every audit. Using major publisher’s practice aids for reference is the most any firm should do on small audits. When we know the requirements of professional standards, it isn’t difficult to tailor or create basic practice aids to guide small audit performance.

These are just a few of the small audit changes CPA firms must consider to increase profits. I’ve designed my Small Audit Series of live and on-demand webcasts to provide holistic solutions that will enable practitioners to make more money on small audits. You can obtain over 300 pages of instructional text materials and illustrative practice aids designed for CPE credit on the left sidebar of our website, www.cpafirmsupport.com. Don’t be left behind! Small audits can generate BIG profits!

Somebody Has Been Busy: PCAOB Issues Eight New Audit Standards

Since the PCAOB was only up to Audit Standard 7 last time we checked and seems to take the conservative approach when it comes to issuing new ones, we have to say we were more than shocked to see them almost double their audit standards overnight. Gee, must be serious.


Via the PCAOB:

The Public Company Accounting Oversight Board today adopted a suite of eight auditing standards related to the auditor’s assessment of, and response to, risk in an audit.

The suite of risk assessment standards, Auditing Standards No. 8 through No. 15, sets forth requirements that enhance the effectiveness of the auditor’s assessment of, and response toial misstatement in the financial statements.

The risk assessment standards address audit procedures performed throughout the audit, from the initial planning stages through the evaluation of the audit results.

“These new standards are a significant step in promoting sophisticated risk assessment in audits and minimizing the risk that the auditor will fail to detect material misstatements,” said PCAOB Acting Chairman Daniel L. Goelzer. “Identifying risks, and properly planning and performing the audit to address those risks, is essential to promoting investor confidence in audited financial statements.”

What does this mean for auditors? Let’s check them out.

AS No. 8 – Audit Risk. This standard discusses the auditor’s consideration of audit risk in an audit of financial statements as part of an integrated audit or an audit of financial statements only. It describes the components of audit risk and the auditor’s responsibilities for reducing audit risk to an appropriately low level in order to obtain reasonable assurance that the financial statements are free of material misstatement.

AS No. 9 – Audit Planning. This standard establishes requirements regarding planning an audit, including assessing matters that are important to the audit, and establishing an appropriate audit strategy and audit plan.

AS No. 10 – Supervision of the Audit Engagement. This standard sets forth requirements for supervision of the audit engagement, including, in particular, supervising the work of engagement team members. It applies to the engagement partner and to other engagement team members who assist the engagement partner with supervision.

AS No. 11 – Consideration of Materiality in Planning and Performing an Audit. This standard describes the auditor’s responsibilities for consideration of materiality in planning and performing an audit.

AS No. 12 – Identifying and Assessing Risks of Material Misstatement. This standard establishes requirements regarding the process of identifying and assessing risks of material misstatement of the financial statements. The risk assessment process discussed in the standard includes information-gathering procedures to identify risks and an analysis of the identified risks.

AS No. 13 – The Auditor’s Responses to the Risks of Material Misstatement. This standard establishes requirements for responding to the risks of material misstatement in financial statements through the general conduct of the audit and performing audit procedures regarding significant accounts and disclosures.

AS No. 14 – Evaluating Audit Results. This standard establishes requirements regarding the auditor’s evaluation of audit results and determination of whether the auditor has obtained sufficient appropriate audit evidence. The evaluation process set forth in this standard includes, among other things, evaluation of misstatements identified during the audit; the overall presentation of the financial statements, including disclosures; and the potential for management bias in the financial statements.

AS No. 15 – Audit Evidence. This standard explains what constitutes audit evidence and establishes requirements for designing and performing audit procedures to obtain sufficient appropriate audit evidence to support the opinion expressed in the auditor’s report.

Now don’t get me wrong, I love rules and regs as much as the next girl – if not more – but I am of the thought that users of financial statements would be better served not by more rules and regs but by a more comprehensive auditor training program that starts in college. Am I asking too much?

Did we really need clarity on audit evidence? The PCAOB seems to think so and that’s fine, they are well-intentioned in their motive and you can’t fault them for that.

(UPDATE) The PCAOB’s Statement on the Signing of The Dodd-Frank Act Isn’t Exactly Enthusiastic

~ Includes statement from PCAOB spokesperson

Hey! Did you hear? Dodd-Frank got signed into law yesterday and plenty of people are excited (namely Dodd, Frank, BO) and there are plenty who are not.

The PCAOB, it seems, lands somewhere in the middle. Sure the dopes exempted public companies with market caps under $75 million from complying with 404 but putting things in perspective, the Board is probably just amped that the SCOTUS didn’t kick them off the playground.


To show their gratitude, the PCAOB doesn’t bother mentioning the exemption in their press release from yesterday, instead focusing on…foreign auditor oversight (pretty much a black hole) and authority over auditors of broker-dealers. We understand that playing nice is part of the game but COME ON.

We emailed the nice folks over at the Board to ask them about the 404 exemption but we’re still waiting to hear back from them. Perhaps they’re putting on their smiley faces to address this one since they’ve probably been gritting their teeth for the last 20 or so hours.

A PCAOB spokesperson provided us with the following statement:

The PCAOB believes that the internal control audit report required under SOX Section 404(b) has improved the reliability of financial reporting and audit quality. The Board has taken steps to make sure that the internal control auditing standard is scalable to companies of all sizes and has issued guidance and held educational forums to assist smaller company auditors in understanding how to apply that standard to smaller companies. The internal control audit requirement relates to the content of SEC filings, and SEC Chairman Schapiro opposed the exemption for non-accelerated filers.

So, in other words, the compliance technically falls under the SEC and the PCAOB issues the audit standards but it still has to hit a little close to home.

BPR:

PCAOB STATEMENT UPON SIGNING OF THE DODD-FRANK WALL STREET REFORM AND CONSUMER PROTECTION ACT
Washington, D.C. , July 21, 2010

Today’s enactment of the Dodd-Frank Wall Street Reform and Consumer Protection Act facilitates the PCAOB’s ability to share information with foreign auditor oversight authorities and closes gaps in the Board’s authority to oversee audits of brokers and dealers.

While the Sarbanes-Oxley Act of 2002 protects the PCAOB’s inspection and investigative processes from public disclosure, it permits the Board, in certain circumstances, to share information with federal and state authorities. However, at the time the Sarbanes-Oxley Act was enacted, very few other countries had audit oversight bodies and, therefore, there was no provision in the Sarbanes-Oxley Act authorizing the PCAOB to share information with foreign authorities. Since that time, many countries have established or are in the process of establishing audit oversight bodies. The Dodd-Frank Act allows the Board, under certain circumstances, to share information with such foreign auditor oversight authorities.

The Dodd-Frank Act also expands the PCAOB’s authority to oversee auditors of brokers and dealers. Under the Sarbanes-Oxley Act, auditors of brokers and dealers were required to register with the Board. The Dodd-Frank Act provides the PCAOB with standard-setting, inspection and disciplinary authority regarding broker-dealer audits.

More information about the PCAOB’s plans to implement this authority and guidance for auditors of brokers and dealers will be forthcoming.

PCAOB Report States That There Was a Fair Amount of Failing Going on at Ernst & Young

The PCAOB has issued its annual report on Ernst & Young having given the firm the third degree at its national office and 30 of its 80 U.S. offices. It inspected 58 audits performed by the firm but exactly who is, of course, a big secret (unless you tell us).

There were five “Issuers” that were listed in the report and some form of the word “fail” was used 25 times (that includes the footnotes).

[Issuer A] The Firm failed to adequately test the issuer’s loan loss reserves related to certain loans held for investment. Specifically, the Firm failed to reconcile certain values used in the issuer’s models with industry data, failed to test the recovery rates used in the issuerfailed to test the qualitative components of the reserves.

Damn those loan loss reserves!

[Issuer C] The Firm failed to perform sufficient procedures to test the issuer’s allowance for loan losses (“ALL”). The issuer determined the general portion of its ALL estimate, which represented a significant portion of the ALL, using certain factors such as loan grades. Data for this calculation were obtained from information technology systems that reside at a third-party service organization. The Firm relied on these systems, but it failed to test the information-technology general controls (“ITGCs”) over certain of these systems, and it failed to test certain of the application controls over these systems. Further, the Firm’s testing of the controls over the assignment and monitoring of loan grades was insufficient, as the Firm failed to assess the competence of the individuals performing the control on which it relied.

This loan thing appears to be a trend…

[Issuer D] The Firm failed to sufficiently test the costing of work-in-process and finished goods inventory. Specifically, the Firm’s tests of controls over the costing of such inventory were limited to verifying that management reviewed and approved the cost allocation factors, without evaluating the review process that provided the basis for management’s approval.

Hopefully that doesn’t blow back on an A1.

Anyway, you get the picture. The whole report is below for your reading pleasure. E&Y’s got its $0.02 in, however it was short and was mostly concerned about the firm’s right to keep its response to Part II (the non-public part)…non-public:

We are enclosing our response letter to the Public Company Accounting Oversight Board regarding Part I of the draft Report on 2009 Inspection of Ernst & Young LLP (the “Report”). We also are enclosing our initial response to Part II of the draft Report.

We note that Section 104(g)(2) of the Sarbanes-Oxley Act requires that “no portions of the inspection report that deal with criticisms of or potential defects in the quality control systems of the firm under inspection shall be made public if those criticisms or defects are addressed by the firm, to the satisfaction of the Board, not later than 12 months after the date of the inspection report.” Based on this statutory provision, we understand that our comments on Part ii will be kept non-public as long as Part ii of the Report itself is non-public.

In addition, we are requesting confidential treatment of this transmittal letter.

So this doesn’t mean much other than E&Y would prefer that no one know how it managed to tell the PCAOB to fuck right off as nicely as it could.

If you had the pleasure of being on one of these 58 engagements, we’d love to hear about your experience.

2010 Ernst Young LLP US

PwC May Have Overlooked Billions in Illegal JP Morgan Transactions. Oopsie.

Now £15.7 billion may not seem like much to you if you are, say, Bill Gates or Ben Bernanke but for PwC UK, it may be the magic number that gets them into a whole steaming shitpile of trouble.

UK regulators allege that from 2002 – 2009, PwC client JP Morgan shuffled client money from its futures and options business into its own accounts, which is obviously illegal. Whether or not JP Morgan played with client money illegally is not the issue here, the issue is: will PwC be liable for signing off on JPM’s activities and failing to catch such significant shenanigans in a timely manner?


PwC did not simply audit the firm, they were hired to provide annual client reports that certified client money was safe in the event of a problem with the bank. Obviously that wasn’t the case.

The Financial Reporting Council and the Institute of Chartered Accountants of England are investigating the matter, and the Financial Services Authority has already fined P-dubs £33.3 million for co-mingling client money and bank money. That’s $48.8 million in Dirty Fed Notes if you are playing along at home.

Good luck with that, PwC. We genuinely mean that.

Inquiries mount after PwC ‘failed to notice’ mistakes [Times UK]

Just Because Cloud Companies Pay For a SAS 70 Doesn’t Make It Any Less Legit, Does It?

Confession: not 100% sure on the hype surrounding SaaS, cloud computing, living in the cloud and whatever but apparently it’s the next big thing (if it’s not already) and might make our lives just one notch short of Jetsons flying car awesome.

Ask guys like Geoff, he’ll tell you all about it. I buy it and I don’t even need to use it, have heard amazing things, and have even evangelized it once or twice.

But it’s your data so instead of jumping on the SaaS/Cloud bandwagon without asking what happens to it once you do, it might be wise to check out the SAS 70 certification and the strange relationship that legitimizes it.


Complying with the AICPA lends a certain bit of credibility to vendors who want to show how tight their control systems are so auditors can rely on them, right?

Perhaps not, says Jay Heiser via Gartner in “Analyzing the Risk Dimensions of Cloud and SaaS Computing,” who is concerned by a sense of deja vu between the faulty systems that collapsed throughout the financial crisis and cloud computing. In an extremely risk-adverse environment, a bit of caution is due before jumping head first into the unknown.

Or you can just trust the shiny marketing materials and forget that it’s your data.

Now back to cloud computing and SAS 70. Okay, let me get this straight: So the cloud companies pay accounting firms for SAS 70 certifications just as the financial organizations paid Moody’s for an investment-grade rating?

“Yes, if you see someone who claims to be SAS 70, they have paid an accounting firm. Not only have they paid an accounting firm to go do the test, but they’ve told the accounting firm what processes need to be tested,” Heiser says.

And that’s different from an audit client paying an auditor how?

In a financial crisis corollary, Big 4 opinions are fetching less these days than they used to. Cloud computing marketers don’t really get what they are pushing but cloud provider clients certainly should understand what this means for the shift to life in the cloud.

Better start updating those marketing materials.

How Cloud Computing Security Resembles the Financial Meltdown [Datamation]

Three Examples of “Significant Unusual Transactions” that Should Get Auditors’ Attention

The PCAOB issued a friendly reminder yesterday to auditors that sometimes unusual transactions can be cause for alarm and should send the risk red flags flying. Unfortunately, the friendly reminder did not actually mention anything about what “unusual transactions” are but regardless, you better be on the lookout for them.

“The PCAOB’s message to auditors, in this challenging economic environment, has consistently emphasized attention to audit risk and adherence to existing audit requirements,” said Martin F. Baumann, Chief Auditor and Director of Professional Standards.

Since Practice Alert No. 5 (makes it sound kind of hot, don’t it?) warns of the risk of material misstatement inherent to unusual transactions without mentioning what those transactions could be, we came up with three unusual transactions to which the PCAOB could possibly be referring. It isn’t called guidance for nothing, you’re on your own when it comes to determining what qualifies as unusual, little auditors. Hopefully this helps.

• Large and frequent A/P entries to an entity known only as “Candy” (substitute “Bubbles”, “Kitty”, or “Roxy” as appropriate) This is why you have professional judgment so use it, we’re pretty sure even if you haven’t been to a strip club you know what strippers look like on the books and records.

• If you find yourself in a warehouse on December 31st counting an inventory full of dirty bombs, AK-47s, plutonium rods, chances are your entity is engaged in “unusual transactions.” Bonus points for extra unusual if you’re counting that crap and your entity is a church. Red flag, dear auditor, red flag!

• Recurring transactions for “crack” are definitely unusual. You don’t need us to tell you that’s a giant red flag, unless you are auditing under the influence yourself and concerned mostly with where the entity’s CFO hides his stash. Remember also that crack is pretty cheap on the street so repeated transactions will likely fall outside the scope of materiality though a raging crack habit will be material in the aggregate. Adjust scope accordingly.

PCAOB Issues Staff Audit Practice Alert on Auditor Considerations of Significant Unusual Transactions [PCAOB]

Dennis Nally: PwC’s Credibility with Our Clients Is Doing Just Fine, Thankyouverymuch

Awhile back we told you about PricewaterhouseCoopers Global CEO Dennis Nally admitting that the PwC brand had been damaged because of the whole Satyam fraud.

DN has done another interview with the Indian press and he says despite this litng is on the up and up in India for PwC. The long/short of it is that Dennis & Co. are going to keep giving their clients the P. Dubs experience now and forever.

Pretty wide range of questions but we’ve presented the highlights for you.


Was the PwC Magic 8ball broken?

Q: When you look back at it do you think you could have avoided all that happened?

A: I don’t know if we could have avoided it. As we all know this was probably one of the most significant frauds that suddenly has taken place here in India but even in the global market place. So I do not know how you avoid that type of situation.

Where was the P. Dubs swagger when the shit hit the fan? Did you realize that everything was f’d and didn’t know what to do?

Q: [T]he firm didn’t seem to respond in a confident manner. The impression was that it didn’t know what it had been hit by. Do you think it could have been handled better?

A: I think with hindsight you can always do things better and that is part of learning and trying to deal with issues. But quite frankly this was a major event and of course it took us time to understand the pattern and what transpired.

In fact we are still learning and everybody is still learning. Now all the facts aren’t quite out yet but I think we are in the business of being out in the public and when something like this happens and it happens in a negative way, we are part of that. That is just a reality of being in a profession that we are involved with.

Why is this PwC’s fault?

Q: What role did the auditors have to play?

A: You are into an interesting debate and discussion because what is the role on a professional standards for the detection of a fraud. That is one of the areas that has been the focus not only on Satyam but a broader profession wide issue and we certainly welcome that debate.

I think there is an expectation out there in the public that auditors uncover every single fraud that they are involved with and that is not what professional standards call for but there is the public perception that that is what we are there to do. I define that as the expectation gap. If that is the expectation then we need to make sure that we are focused on the right kind of procedures, the right kind of standards, the right kind of reporting which is quite frankly really different than what we do today.

Will you stop all future frauds in India forever and ever and ever?

Q: Can you tell us if India will never see a Satyam again?

A: I wish I had a crystal ball but I don’t. As I said when you have a situation like Satyam or a major fraud I suspect somewhere in the world of corporate reporting, you are going to see another situation like that. Our job is to make sure we are doing everything we can possibly do consistent with the standards that are out there to ensure that we play our role in that process to avoid them.

The new India managing partner came from Singapore? You got something against Indians?

Q:But he has not come from India, you didn’t appoint him from the India firm – he was brought in from Singapore?

A: Gautam is originally from India which is great so it’s little bit of coming home programme.

Q: But it’s not a vote of confidence on the India management?

A: It is not. This is all about ensuring that we get the very best talent to focus on an important market like India and that’s exactly what we have done.

You let everyone down. Speak to them!

Q: A word to all those investors who felt disappointed with PriceWaterhouseCoopers for not alerting them to what was going on in Satyam. What is your message to them today?

A: Whenever we have situation like this, right or wrong, whatever standards are we are part of that and for that we regret what has happened. But this firm is about quality. It’s about doing the right things, it’s about being here for the investor community and we are very much focused on that.

Satyam fiasco has not dented credibility with clients: PwC [Money Control]

Auditor

Are Big 4 Auditors Irrelevant?

Okay people, the calls for the complete obliteration of the accounting world have begun. Check that. It’s more or less the accounting world as it relates to auditors of public companies (i.e. Big 4 auditors).

Steve Goldstein at MarketWatch, for one, is NOT A FAN, “What precise purpose does it serve to have a supposedly independent auditor (paid for by the company) sign off on accounts? From Enron to Lehman to Satyam to Parmalat, it’s clear that the major accountants lack either the skill or the determination (or both) to ferret out fraud.”


So in case you didn’t catch it, he’s calling into question the Big 4’s (our assumption) integrity, competence and fortitude. Oh and before you start huffing about “it’s not the job of the auditor to detect fraud,” we’d argue that’s not even the point any more. Lehman was engaging in what a former CFO calls “shenanigans” that E&Y knew about for years and went along with it. Why? Because Lehman said everything was kosh.

Goldstein goes on:

Company executives already are forced to sign off on their accounts. When they are caught lying, companies face liability over disclosure.

So the threats that keep (some) companies honest are there regardless of whether the reports are audited. The outside auditors themselves are assigned a negligible value by the market.

A solution? Here’s two admittedly out-there solutions that the Securities and Exchange Commission probably won’t adopt.

One is quite simple: get rid of accountants. Who cares? They add no value, and their expenses weigh on the bottom line.

The other would be for someone else to hire the accountant. How about the company’s top five shareholders? While the likes of Fidelity would grumble about the added costs and the free-rider benefit for smaller shareholders, they would certainly have an interest in securing a far tougher audit.

Okay, Big 4 auditors, here’s your homework: explain why auditing for public companies isn’t irrelevant. We’ll listen, we swear. Or just start shooting off at the mouth if you feel it necessary. Goldstein isn’t the first to make this determination. Francine McKenna and Jim Peterson have argued that the value of an auditor’s opinion has been nil for quite some time and they’re both Big 876454 alums. It’s okay if you admit it. Acceptance is the first step.

What exactly is the point of having accountants? [MarketWatch]

Lehman Brothers sign removal

Ernst & Young Was ‘Comfortable’ with Lehman’s Shady Accounting

Late yesterday, U.S. Bankruptcy Examiner Anton Valukus released a 2,200 page report that details the collapse of Lehman Brothers. It points the finger at Lehman execs for engaging in shady accounting that Ernst & Young knew about and was comfortable with. Lehman’s Board of Directors were not informed of the questionable accounting treatment.

To put it in more technical terms: Ernst & Young is in deep shit. The lead partner on the Lehman audwed more times than Dick Fuld for crissakes.

The accounting in question was known inside Lehman as “Repo 105.” These transactions moved billions of dollars off of Lehman’s balance sheet that were described by emails in the report as “basically window dressing” and their global financial describing them as having “no substance.” The Times reports that the treatment was so crucial to LEH that one executive, Herbert McCade, was known internally as the “balance sheet czar” and that he described in an email that the treatment was “another drug we r on.”


The really bad part for Ernst & Young is that they were okay with the “drug.” From the report, the lead partner stated that E&Y “had been aware of Lehman’s Repo 105 policy and transactions for many years.” For you wonky types, Lehman was accounting for these “Repo 105” transactions based on guidance from Statement on Financial Reporting Standard 140, Accounting for Transfers of Financial Assets and Repurchase Financing Transactions.

E&Y’s “team had a number of additional conversations with Lehman about Repo 105 over the years,” although they were not involved with drafting the policy nor did the firm provide any advisory services related to the transactions. According to the lead partner on the engagement, the firm simply “bec[a]me comfortable with the Policy for purposes of auditing financial statements.”

The problem, according to the Examiner’s report is that E&Y was okay with the treatment based on the theory:

Ernst & Young’s view, however, was not based upon an analysis of whether actual Repo 105 transactions complied with SFAS 140. Rather, Ernst & Young’s review of Lehman’s Repo 105 Accounting Policy was purely “theoretical.” In other words, Ernst & Young solely assessed Lehman’s understanding of the requirements of SFAS 140 in the abstract and as reflected in its Accounting Policy; Ernst & Young did not opine on the propriety of the transactions as a balance sheet management tool.

According to Lehman’s Global Financial Controller Martin Kelly, “Ernst & Young ‘was comfortable with the treatment under GAAP for the same reasons that Lehman was comfortable.'” Don’t you love it when things work out like that?

Ernst & Young has issued a statement that simply addresses the final audit that the firm performed: “Our last audit of the company was for the fiscal year ending Nov. 30, 2007. Our opinion indicated that Lehman’s financial statements for that year were fairly presented in accordance with Generally Accepted Accounting Principles (GAAP), and we remain of that view.”

SO! E&Y is in a bit of a pickle. Civil suits have already been filed against both firms and more investigations will certainly be coming. If you’ve got some time over the weekend, take a flip through this beauty. We know there is accounting porn in there for some of you.

Report Details How Lehman Hid Its Woes as It Collapsed [NYT]
Examiner: Lehman Torpedoed Lehman [WSJ]
Lehman Brothers Holdings Inc. Chapter 11 Proceedings Examiner’s Report [Jenner & Block]

Preliminary Analytics | 12.21.09

angelo_mozilo.jpgHealth-care bill clears crucial vote in Senate, 60 to 40 – “The vote was the first of three procedural hurdles that Democrats must cross before a final vote on passage of the measure, now scheduled for Christmas Eve.” [Washington Post]
Bye-bye Bo-Tax. Hello, Tan Tax – Angelo Mozilo will not stand for this. [Don’t Mess With Taxes]
Top Ten Ways to Ensure a Smooth Audit – Communication seems to be a theme. There’s a concept. [Mission Accountable]
An Inside Look at JPMorgan Outplacement [FINS]
Dubai World poised to press for loan extensions – No word if DW plans on actually paying the loans back. [Reuters]
IRS Files $8.15 million in Tax Liens Against Sinbad – Despite filing tax returns, Sinbad didn’t pay the tax owed from 1998 to 2006. [TaxProf Blog]
2009: The Year of the Failed Banks – Seven more this past Friday, bringing the total to 140. [The D&O Diary]

UK Regulators: Let’s Try and Quantify Audit Quality

RG-1031.jpgOur friends across the pond have put it out there that as it stands, an audit report is an audit report is an audit report. Regardless of the firm doing the work, the end product is the same and the Professional Oversight Board (POB) wants audit firms to produce, “more quantitative data to better equip investors and companies with the tools needed to scrutinise their auditors.”


It’s long been popular to call an auditor’s product a “commodity” and this appears to be the Brits’ attempt to dispel that notion. The talk of asking auditors to somehow quantify quality has already garnered support in the investing community in the UK:

Michael McKersie, assistant director capital markets at the [Association of British Insurers], said he would welcome more comparative information. “The relative lack of hard quantitative reporting data on the audit firms and global networks has been… a concern. Comparability is really important and we have, in the past, seen no n-comparability [sic] here as a problem.”

Fine idea, although there’s not a single indication of how the quality could be measured and the director of auditing at the POB even admits that ‘The challenge is how can auditors demonstrate quality and those that use their services assess it.’
This whole idea of “comparability” came up because of a POB inspection of showed, “some firms were rewarding staff for attracting business at the expense of promoting audit quality.” So the answer to this problem — from the POB’s point of view — is to slap together a “rate this audit from 1 to 10” system and the firm with the highest score has the best audits?
Audit firms will always claim that their work is of the highest quality regardless of the circumstances but now regulators want them to put that in some quantifiable form. And because we like to keep the pace with our friends in the UK, it probably won’t be long before an ambitious bureaucrat Stateside (e.g. new PCAOB Chairman) will insist on a similar approach.
If there’s any wonky auditors out there that have some ideas how this could be done, we’re all ears but for now we’re firmly in the skeptical camp.
Clients blind on audit quality [Accountancy Age]
Also see: You mean the Big 4 aren’t transparent? [Tax Research UK/Richard Murphy]