PCAOB Inspection Reports

Meddling Inspectors

The PCAOB Needs to Just Beat the Sh*t Out of KPMG Already

Story time. Many, many years ago when my favorite show was the Snorks and my Big Wheel was my only mode of transportation, there was this kid on my block who was a real little shit. He constantly broke everyone’s toys and once ran over my plastic Good Luck Bear with his bike, permanently rendering […]

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Deloitte’s 2017 PCAOB Inspection Report Is Pretty Not Shitty

You know, when I sat down to start writing this, I contemplated some clever headline, perhaps something about a veritable smorgasbord of audit screw-ups, but then I was like, you know what, nah. We should recognize that Deloitte has posted its lowest audit deficiency rate ever, which is something worth applauding even if the fuck-up rate […]

Where, Oh Where, Is KPMG’s 2016 Inspection Report?

KPMG’s 2016 inspection report has still not been published by the Public Company Accounting Oversight Board, and the PCAOB won’t say why—or if the report will ever see the light of day. Compliance Week reports: The Public Company Accounting Oversight Board published its 2016 inspection results for Deloitte in December 2017 followed by reports for EY […]

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PCAOB Inspection Reports Are Practically Beach Reads Now

Over the years, people have complained — myself included — that PCAOB inspection reports were not exactly useful documents. Sixty-odd pages of audit and legalese don’t exactly make for riveting content. However! In the new EY and PwC inspection reports that were released today, you’ll note executive summaries that list tables for the “Effects of […]

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Big 4 Audit Quality Hiding in Plain Sight: Restatement Mentions in PCAOB Reports

For the last several years, one very interesting audit quality metric has not been widely reported in the media, and the largest audit firms barely mention it. It has been hiding in plain sight and could be a useful data point to audit committees or investors that are trying to understand the quality of audits. […]

PCAOB Inspectors Find IT Auditors on the Struggle Bus

In case you missed the news earlier this month, all of the PCAOB reports are out for the Big 4's 2015 cycle of inspections. What schadenfreude awaits us? Let’s take a look. Big picture — regarding overall deficiency rate — PwC is the winner this year. Even if PwC is only slightly ahead, the firm […]

KPMG’s PCAOB Inspection Report Is Out and It’s Not Good

Oh boy, KPMG's PCAOB inspection report is finally out. Michael Rapoport at the Wall Street Journal has the lowdown:

Hey Look, McGladrey’s PCAOB Inspection Wasn’t So Good

The PCAOB released its inspection report for the accounting firm soon-to-be-formerly-known-as McGladrey yesterday and it's not the best but it's not the worst, either. Out of 15 audits selected, the inspectors found deficiencies in 7 of them. Most of the issues related to AS No. 5 and AS No. 13. It's all pretty shrug but […]

PwC Out of the Running for This Year’s “Worst Performance By a Big 4 Audit Firm”

The PCAOB, bless their hearts, released a forgettable inspection report from PwC today. The deficiency rate, 29%, is still in the range we're used to, but was lower than last year, so that's something. Michael Rapoport reports that this deficiency rate is better than EY's (36%) but not as good as Deloitte's (21%) and that […]

PCAOB Inspection Report Shows That EY’s Auditing Is Still Bad

Maybe you've noticed, maybe you haven't, but PCAOB inspection reports have loads more information in them than they used to. They have several tables that summarize deficiencies by audit standards, financial statement accounts/audit areas and industry. They also throw in pie charts to show the breakdown of the industries and revenues ranges of the companies […]

PCAOB Inspection Report Gives Grant Thornton Another Swift Kick in the AS5

Just when you thought, "Boy, it's been awhile since I've seen a terrible PCAOB inspection report," here comes the PCAOB with a terrible inspection report. It's like Christmas! Well, for those of us who find this entertaining, anyway. For Grant Thornton, not so much. Out of reviews of portions of 36 audits, PCAOB inspectors found […]

Auditor Phones in Auditing Revenue, Gets Totally Busted

The PCAOB posted 26 new inspection reports today, none of which were all that remarkable. But we did take a peek at MaloneBailey's, where we found this little nugget from Issuer C: In this audit, the Firm failed to perform sufficient procedures to determine whether the issuer properly recognized revenue. The issuer manufactured custom products […]

Those Who Know, Know BDO Got Their AS5 Kicked in Latest PCAOB Inspection Report

Another day, another PCAOB report. Today, our lucky victim is BDO USA, LLP. Of the 23 audits inspected, the PCAOB found deficiencies in 15 of them. For those of you playing along that home, that puts them at a 65% failure rate which means they are in the lead for crappiest audits in America of […]

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 […]

PCAOB Inspection Report Hands KPMG Its AS5

Oh, man. The last remaining Big 4 inspection report of 2013 was released by the PCAOB today and we are proud to be the first to tell you, KPMG did not come in last as the haters might have expected. For two of the 50 audits inspected, KPMG was not the primary auditor but just […]

EY Hits 50% Failure Rate on PCAOB Inspection, Gets a Grade of LOL on AS5

Today, the PCAOB released its latest inspection report on the firm formerly known as Ernst & Young. Now, before we get into that, let's get into a little history because everyone loves history, right? EY boasted an impressive failure rate of 35.7% in 2011, which was followed up by an even more impressive failure rate […]

PwC Slightly Better at Auditing This Year, Says PCAOB Inspection Report

Rejoice, people, PCAOB Inspection Report season continues! From PwC's fresh off the presses 2013 inspection report: The 2013 inspection of the Firm included reviews of portions of 57 audits performed by the Firm and reviews of the Firm's audit work on two other issuer audit engagements in which the Firm played a role but was […]

Deloitte Kicks off PCAOB Inspection Season with a Respectable Failure Rate* (by Deloitte Standards)

Oh lookie here, PCAOB inspection reports are out today. We shall gloss over Mantyla McReynolds, LLC and CF & Co., L.L.P, going straight to what we want. Deloitte is first out of the gate for the 2013 inspection season, perhaps due to the fact that 52 audits were inspected and only a measly 15 deemed […]

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 […]

McGladrey’s Latest PCAOB Inspection Reveals McGladrey Is Not Grant Thornton

Well, the PCAOB is slowly but surely cranking out more 2012 inspection reports and today, McGladrey gets to celebrate an accomplishment: being better at auditing than Grant Thornton (though I suppose given GT's embarrassing audit failure rate, that isn't saying much). Not only that, they're slightly better than EY and only slightly worse than PwC. […]

Crowe Horwath’s Latest PCAOB Inspection Report is Bad But Not as Bad as Last Year

Clearly the fine folks at Crowe weren't following SALY, as their batting average has improved slightly over their last report. And by slightly we mean they got it right half of the time in 2012, which is still better than Grant Thornton and BDO. Still, it looks like AS 5 is to auditors as a […]

So BDO Isn’t That Good at Auditing Either, But Still Better Than Grant Thornton

Now this is just getting funny. And by funny I mean sad. The PCAOB has released its 2012 inspection report on BDO and the news isn't nearly as bad as it was for Grant Thornton so, well, there's that. Which really isn't much when you think about it but… hey… gotta take what you can […]

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 […]

PwC and KPMG Inspection Reports Make Us Wonder: Are Shoddy Big 4 Audits Here to Stay?

Have we mentioned how much we enjoy the PCAOB releasing inspection reports and/or making big announcements the week leading up to a major holiday? No? Oh yes, it's right up there with root canals and saddle sores. But it's their labor of love so we'll share the news with you. Today, the Board released the 2012 […]

Ernst & Young’s PCAOB Inspection Report Results Managed to Get Much Worse

Just yesterday we ran down the 2011 performance of the eight largest public accounting firms in this fair land. And just as soon as people were starting to get their knickers in a twist, the PCAOB released its 2012 inspection report for the firm formerly known as Ernst & Young. And yes, the firm's error […]

Deal Between PCAOB, Chinese Is a Lose-Lose Situation

Yes, the PCAOB got a lousy deal by putting Jim Doty's name on the Memo of Understanding with China's Securities Regulatory Commission and Ministry of Finance, but Professor Paul Gillis writes in the Wall Street Journal that the Chinese don't have any room to talk, either: Without inspections, investors can't trust Chinese audits. Investors in Chinese […]

Would You Rather: Have Part II of PCAOB Inspection Report Released or Find Out an Audit Partner Passed Along Inside Information?

Oh, to be a Big 4 firm these days. Yes, billions of dollars flow in from every corner of the world thanks to your professional services, but thanks to the audit practice, there's peril around every corner!  The news that former KPMG audit partner Scott London passed along inside information to someone outside the firm […]

At Least PwC Doesn’t Have to Worry About Improving the Supervision of Its Auditors Anymore

Last week the PCAOB dropped Part II of PwC's 2008 and 2009 inspection reports. This was only the second time a Big 4 firm's Part II had been released since the audit profession was blessed with government regulation. It was like a fire rainbow or an unassisted triple play. Rare! Exciting-ish! We pored over the […]

PCAOB Not Satisfied with PwC’s Efforts to Get Better at Auditing

Deba Aubin at Reuters has a great scoop this morning, reporting that the PCAOB "will fault PwC for not promptly addressing quality control problems found during inspections of some of its 2007 and 2008 audits," according to an internal PwC memo dated today and signed by Bob Moritz. [cue]

BDO Keeps Pace with Rival Audit Firms in Terrible PCAOB Inspection Reports

For whatever reason, BDO was excluded in the last-minute lump of coal the PCAOB delivered to Deloitte, Ernst & Young, and Grant Thornton right before Christmas, but that doesn't mean their inspection report wasn't in the same class of quality.  The Board inspected audits at 16 of BDO's 35 offices, inspecting 23 audits with 9 […]

Deloitte Rewards Auditors for Job Well Done with Professional Skepticism Homework

On December 21st, long after most people had given up on the world coming to an end and just about the time everyone on the east coast was about to check out for the rest of 2012, the PCAOB conveniently released the 2011 inspection reports for Deloitte, Grant Thornton, and Ernst & Young. The timing […]

PwC Wants the PCAOB To Get Better

PwC's November just got more annoying. According to the PCAOB's latest inspection, 41 percent of the 60 PwC audits inspected were not up to snuff, up from 37 percent last year. Issues called out by the PCAOB included failures to identify, or to address appropriately, financial statement misstatements, including failures to comply with disclosure requirements, as […]

Big 4 PCAOB Inspection Reports to Be SALY

If a person was going to describe the 2010 PCAOB inspection results, you might hear things like, "didn't meet expectations" or "downright embarrassing" or "an abomination" or they may just make Hans Hoogervorst's favorite hand gesture. Simply, they weren't so good. The good news is there's no place to go but up. The bad news is […]

KPMG’s PCAOB Inspection Report Shows Firm’s Audit Quality Was Consistently Meh with Last Year

Late yesterday the PCAOB released the first Big 4 firm inspection report with none other than KPMG (in full on page 2). Compliance Week reported that the House of Klynveld more or less stayed consistent with last year's findings, which basically amounts to everyone shrugging with indifference:  In its first published report from the 2011 […]

Just in Case There Are Audit Committee Members Out There Slacking on the Job, The PCAOB Has Released a Guide to Its Inspections That Should Catch You Up on Things

Are you a member of an audit committee that's been phoning it in? Or are you a newbie that's feeling upstaged by your fellow audit committee buds that are the so-called financial experts? Maybe you're skeptical of the words coming out of your audit firm's piehole(s) but you're not sure how to respond? Fear not! […]

Crowe Horwath May Have the Worst PCAOB Inspection Report Yet

PCAOB Terror Tour 2012 continues with the release of the inspection for Oakbrook Terrace's own Crowe Horwath. Up until this point, we thought that no one was going to make a run at the deplorable performances of Deloitte and McGladrey but ol' Crowe (as opposed to Old Crow) has managed to do it. PCAOB examiners found […]

The Number of Financial Statement Audit Deficiencies Is Blowing Up

So says an analysis of PCAOB inspection report data: The Survey of Fair Value Audit Deficiencies was released Wednesday by Acuitas, Inc., an Atlanta CPA firm that practices litigation and business valuation services. The analysis found that fair value measurement and impairment deficiencies accounted for 52 percent of all the audit deficiencies cited in the […]

The PCAOB Inspection Report of Grant Thornton Could Have Been Worse

The Board inspected 41 audits at 21 of Grant Thornton's 51 offices. Fifteen issuers were cited in the report that included various failures, primarily related to "obtain[ing] sufficient appropriate audit evidence to support its opinions on the financial statements and on the effectiveness of [internal controls over financial reporting]." There was everything from failure to […]

Here’s the Ernst & Young PCAOB Inspection Report for Your Reading Pleasure

Yesterday, we discussed Deloitte stinking up the joint with its PCAOB inspection report. While the firm, at large, probably puts out hundreds of quality audits, the PCAOB gumshoes found that 45% of audits stamped with a green dot had deficiencies. Today, the Board stuffed our stocking with Ernst & Young's inspection report and while it's not […]

As it Stands Right Now, Deloitte Was the Worst Big 4 Audit Firm in 2010

Yesterday, the regulatory love child of Paul Sarbanes and Michael Oxley, the PCAOB, issued its 2010 inspection report for Deloitte. Deloitte was the third Big 4 firm to have their report issued this year with PwC and KPMG being issued just before Thanksgiving. While the reports for both PwC and KPMG were of the "we're […]

In Case the Tryptophan Doesn’t Work, Here Are the KPMG and PwC PCAOB Inspection Reports for Your Reading Pleasure

Actually, if you’re in to this sort of thing, it could make for some pretty interesting reading.


We pointed to a couple of reports this morning (and there are more) out there on the Board’s criticisms of the two firms, so we won’t repeat them here. The most notable thing seems to be each firm’s response to the report. KPMG went with the standard three-paragr��������������������er that promises that they’ll suck less at auditing in the future.

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But as Floyd Norris pointed out, PwC’s Chairman and Senior Partner Bob Moritz as well as Assurance Leader Tim Ryan put their names on the firm’s response to the Board’s inspection that outlined what steps were being taken to improve the audit quality, which is a first. The firm also released this statement from BoMo, acknowledging the slight uptick in deficiencies:

PwC is built on our reputation for delivering quality. We also recognize that the role we play in the capital markets requires consistent, high-quality audit performance. We therefore are focused on the increase in the number of deficiencies in our audit performance reported in the 2010 PCAOB inspection over prior years. We are working to strengthen and sharpen the firm’s audit quality, including making investments designed to improve our performance over both the short- and long-term.

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So you can all this – signatures, action plans, etc. – for what it’s worth but the messaging has certainly changed and it differentiates PwC from KPMG. Will have to wait and see if Deloitte or E&Y follow suit.

KPMG, Center for Audit Quality Weren’t Too Keen on PCAOB Inspection Documents Being Subpoenaed

Last week, we told you about Jonathan Weil’s latest scoop exposing a PCAOB issuer in an inspection report. The issuer in question was Motorola and it, once again, featured KPMG as the auditor on the receiving end of the Board’s criticism. It was also noted that PCAOB Chair Jim Doty mentioned this particular case (without naming names) in his speech at USC the previous week when he described “one large firm tam was aware that a significant contract was not signed until the early hours of the fourth quarter. Nevertheless, the audit partner allowed the company to book the transaction in the third quarter, which allowed the company to meet its earnings target.”

J Dubs put this all together in a nice little package, citing court documents from a class-action lawsuit in Chicago. What isn’t mentioned in Weil’s column but is spelled out in other court documents that we’ve reviewed is that KPMG and the Center of Audit Quality fought the release of the documents related to the PCAOB’s inspection report because they’re afraid that more lawsuits could result if issuers’ identities are made public.

The CAQ submitted an amicus curiae brief (in full on the next page) stating:

The supervisory model of regulation created by Sarbanes-Oxley and implemented by the PCAOB has thus far worked well and has improved the quality and reliability of audits of public companies. It has worked to the satisfaction of both the Board and the regulated community.

Since the PCAOB’s own Investor Advisory Group issued a report entitled “The Watchdog that Didn’t Bark … Again,” one might say that the Center’s final point is debatable.

Yet, the CAQ argued that if the PCAOB inspection documents were released, “the [Sarbanes-Oxley] Act’s carefully supervisory model will be adversely affected.” That is, the confidentiality afforded to the communication between auditors and the PCAOB would be compromised and would allow Board information into the ‘hands of litigating lawyers.’ The CAQ declined to comment for this post, saying that they did not “have anything to add to the amicus brief.”

In her ruling denying KPMG’s motion (in full, on page 3) to squash the subpoena of the PCAOB documents, Judge Amy St. Eve cited KPMG’s argument that sounds very similar to the CAQ’s:

KPMG argues that “if litigants can compel production of materials related to the PCAOB’s confidential inspection process notwithstanding section 105(b)(5)(A), open and constructive engagement between the PCAOB and accounting firms could be chilled by the threat of increased civil litigation, and the statutory framework carefully crafted by Congress to improve the quality of public company audits could be frustrated.”

So basically auditors are afraid that if their super-special-secret discussions with the PCAOB are out there for all the world to see, they’ll get sued more often. But hasn’t suing audit firms already reached critical mass? Can they really fear more litigation? The only thing that keeps audit firms from being on the same level of litigation risk as tobacco companies is that they aren’t killing people.

Weil and those that agree with him argue that the PCAOB owes it to investors to name names in their inspection reports. To continue keeping issuers confidential protects them from legitimate criticism for shoddy accounting and perpetuating equally shoddy audits. Of course, if you’re an investor and that doesn’t bother you, then maybe you’re okay with auditors trying to stop the release of more information related to their work. Work that cost the investors in Motorola $244 million from 2000 to 2010.

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Another KPMG Client Gets ID’d in a PCAOB Inspection Report

Back in March, Bloomberg’s Jonathan Weil called attention to a PCAOB report that was pretty harsh on KPMG-Bermuda’s audit of Alterra Capital Holdings. At the time he wrote the column, KPMG, the PCAOB and Alterra weren’t talking but then Alterra filed a 8-K admitting that they were the filer in question.

Today Weil lets the cat out of the bag again and yes it’s another KPMG client, Motorola:lockquote>Four years ago, inspectors for the auditing industry’s chief watchdog discovered that KPMG LLP had let Motorola Inc. record revenue during the third quarter of 2006 from a transaction with Qualcomm Inc. (QCOM), even though the final contract wasn’t signed until the early hours of the fourth quarter. That’s no small technicality. Without the deal, Motorola would have missed its third-quarter earnings target.

The regulator, the Public Company Accounting Oversight Board, later criticized KPMG for letting Motorola book the revenue when it did. Although KPMG had discussed the transaction’s timing with both Motorola and Qualcomm, the board said the firm “failed to obtain persuasive evidence of an arrangement for revenue-recognition purposes in the third quarter.” In other words, KPMG had no good reason to believe the deal shouldn’t have been recorded in the fourth quarter.

This may sound familiar to some of you that read PCAOB Chairman James Doty’s speech from last week when he said this:

PCAOB inspectors found at one large firm that an engagement team was aware that a significant contract was not signed until the early hours of the fourth quarter. Nevertheless, the audit partner allowed the company to book the transaction in the third quarter, which allowed the company to meet its earnings target. Although the firm discussed the timing of the transaction with the customer, it failed to obtain persuasive evidence of an arrangement for revenue recognition purposes in the third quarter. The company had been an audit client of the firm for close to 50 years.

Weil writes, “KPMG has been Motorola’s auditor since 1959; it had been Motorola’s auditor for 47 years at the time of the Qualcomm deal.” So, yeah. How did he piece this one together? Elementary, my dear auditors:

Motorola’s identity was disclosed in public records last month as part of a class-action shareholder lawsuit against the company in a federal district court in Chicago. The plaintiffs in the case, led by the Macomb County Employees’ Retirement System in Michigan, filed a transcript of a September 2010 deposition of a KPMG auditor, David Pratt, who testified that Issuer C was Motorola. KPMG isn’t a defendant in the lawsuit.

Pratt also identified the Motorola customers cited in the board’s inspection report. It’s his deposition that allows me to describe the report’s findings using real names.

The oversight board said a significant portion of the company’s earnings for the 2006 third quarter came from two licensing agreements that were recorded during the last three days of the quarter. One was the Qualcomm deal that wasn’t signed until the fourth quarter. The board also cited other deficiencies in KPMG’s review of Motorola’s accounting for the transactions.

As is their wont, KPMG isn’t talking. Motorola isn’t talking (but maybe there’s another 8-K in our future?). The PCAOB, bound by the law -which, some say, is debatable – isn’t talking. My guess is that Jon Weil will continue to talk…er…write columns shining the lights on shoddy audits until the Board breaks its silence.

Dirty Secrets Fester in 50-Year Relationships [Jonathan Weil/Bloomberg]

(UDPATE) KPMG-Bermuda’s PCAOB Inspection Gets a Little Unwanted Attention

Most of you are acutely aware that PCAOB inspection reports, while chock full of interesting tidbits, are a little anti-climactic since we never learn who the auditees are. Oh sure, we can speculate until our heart’s content but the PCAOB says they took a vow of silence after 43 struck his signature on Sarbanes-Oxley.

The secrecy is frustrating (read: bor-ing) so it was especially cool to see Jonathan Weil let the cat out of the bag on at least one Big 4 client:

Two weeks ago,Accounting Oversight Board released its triennial inspection report on the Hamilton, Bermuda-based affiliate of KPMG, the Big Four accounting firm. And it was an ugly one. In one of the audits performed by KPMG- Bermuda, the board said its inspection staff had identified an audit deficiency so significant that it appeared “the firm did not obtain sufficient competent evidential matter to support its opinion on the issuer’s financial statements.”

This being the hopelessly timid PCAOB, however, the report didn’t say whose audit KPMG-Bermuda had blown. That’s because the agency, as a matter of policy, refuses to name companies where its inspectors have found botched audits. It just goes to show that the PCAOB’s first priority isn’t “to protect the interests of investors,” as the board’s motto goes. Rather, it is to protect the dirty little secrets of the accounting firms and their corporate audit clients.

That’s why it gives me great pleasure to be able to break the following bit of news: The unnamed company cited in KPMG- Bermuda’s inspection report was Alterra Capital Holdings Ltd. (ALTE), a Hamilton-based insurance company with a $2.3 billion stock- market value, which used to be known as Max Capital Group Ltd.

Using his detective skills, Weil pieced together the number clients KPMG Bermuda had inspected, the timing of said inspections and the details of the audit deficiency (“the failure to perform sufficient procedures to test the estimated fair value of certain available-for-sale securities”) to come up with Alterra. Of course no one – the PCAOB, KPMG Bermuda or Alterra – would comment/confirm for Weil’s column but you probably knew that was coming. Nevertheless, JW gets into the how bad of an audit this really was:

It’s when you look at Alterra’s financial statements that the magnitude of KPMG-Bermuda’s screw-up becomes apparent. Available-for-sale securities are the single biggest line item on Alterra’s balance sheet. They represented almost half of the company’s $7.3 billion of total assets as of Dec. 31, 2008, and a little more than half of its $9.9 billion of total assets at the end of last year.

This sort of screw-up, some might argue, falls somewhere in the range of “horrendously bad” and “really fucking bad” and Weil wonders if Alterra shareholders will have the stones to throw the bums out at the shareholders meeting on May 2. We can’t say where any of the shareholders stand on the usefulness (or lack thereof) of the audit report, so maybe this revelation is NBD to them. But if that is the case, it seems to make an even stronger case for the irrelevancy of auditors.

Weil’s larger point is that the PCAOB continues to hide behind their policies that are supposed to protect investors but in reality come off as talking points, not so unlike the firms they regulate. The PCAOB says they’re working on that but we’ll have to wait until summer to find out how crazy things get and whether it will be enough to shove auditors back into some respectability.

Dirty Little Secret Outed in Bermuda Blunder [Jonathan Weil/Bloomberg]

UPDATE:
Alterra cops to it with an 8-K that was filed about 90 minutes ago:

Alterra is aware of a recently issued report by the Public Company Accounting Oversight Board (the “PCAOB”) related to the PCAOB’s review of KPMG Bermuda’s 2008 audit files of a public company client located Bermuda, as well as an article posted on Bloomberg that indicates that the public company client is Alterra (formerly Max Capital Group Ltd.). Alterra confirms that it is the client referenced in the PCAOB’s report.

The PCAOB report findings question the sufficiency of procedures performed by KPMG Bermuda in its audit of Alterra’s estimated fair value of certain available-for-sale securities as promulgated by generally accepted audit standards (“GAAS”). The PCAOB report questioned whether the audit procedures used by KPMG Bermuda in 2008 to verify such values were sufficient. The PCAOB report does not question the appropriateness of the values that Alterra attributed to assets available-for-sale in 2008.

Alterra notes that the PCAOB made substantially similar findings in a number of inspections of 2008 and 2009 audits performed by the larger accounting firms and, since 2008, we understand the firms have issued additional guidance to clarify the work to be completed on the audit of fair value investments.

KPMG Bermuda has represented to Alterra and its Audit Committee that it believes it properly and appropriately followed GAAS as defined at the time of the audit. KPMG Bermuda confirmed in its response to the PCAOB report that “none of the matters identified by the PCAOB required the reissuance of any of our previously issued reports.” Alterra reaffirms its belief that the asset values ascribed to its available-for-sale securities in 2008 and subsequent periods remain appropriate.

KPMG Bermuda issued an unqualified opinion for Alterra’s year end financial statements for each of 2008, 2009 and 2010.

Is Citi One of the Issuers in the PCAOB’s Inspection Report of KPMG?

The long-awaited PCAOB inspection report of KPMG came out on Friday and while we were excited for this unveiling, the Board managed to issue the report at around 4 pm on Friday. Since the Board lacks any sense of timing whatsoever, we opted to punt on our respective post until today because well, we’re human and not a soulless blogging robot as likely perceived by TPTB at the PCAOB.

It’s worth mentioning that this is the first PCAOB report that has been issued since the SEC’s final rule on the inspections that allows audit firms to postpone the release of the report simply by taking issue with any of the findings. Since any appeal could reportedly delay the report by “30 to 100 days,” it’s safe to assume that, with a report date of October 5th, KPMG didn’t have a beef with the findings. You could also assume that since the SEC is taking a peek at these reports now, there’s going to be a ten day lag on the release of the report to allow the Commission enough time to give it their extra-special sniff test.

Anyway, back to the matter at hand –

KPMG had eight issuers noted in the Board’s inspection report and the first two are doozies. “Issuer A” runs approximately two pages and includes failure on testing of “allowance for loan losses” to “test[ing] the issuer’s estimates of fair values of financial instruments” and goodwill impairment.

“Issuer B” is a little more interesting since one of the failures the Board found was related to deferred tax assets which makes us wonder if this is Citi, since analyst Mike Mayo was loudly questioning the bank’s treatment of its DTA. Francine McKenna not-so-subtly solicited guesses on Friday as to who this “bank” might be (even though no issuer is identified as such) but it does make us wonder.

The Board cites run-of-the-mill failures for the rest of the issuers (e.g. fair value testing, pension plan testing, failure to confirm cash[!]) and the House of Klynveld’s response letter was cordial and anticlimactic.

But if you’re KPMG, do you really care what the PCAOB thinks when you’ve got an adorable gnome-ish looking analyst giving you the tepid thumbs-up (despite not knowing your name)? That’s the only endorsement we would need.

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Is the SEC Taking the “O” Away from the PCAOB?

The PCAOB has had a pretty good run of late. It all started with the SCOTUS handing them a loss that was really a win and the Board has, most recently, gotten ambitious with new risk assessment standards. What’s more is the call of acting Chair Dan Goelzer to have the Board’s enforcement inspections held publicly so audit firms can’t get all mysterio about what they did and did not do to warrant said inspection.

Well, the run of luck appears to have come to an end as the SEC issued a new rule that takes effect next month that marginalizes the Board to the benefit of the accounting firms it oversees (our emphasis).

Going into effect September 7, the rule explains how accounting firms can dispute the PCAOB’s findings during its inspection process. The firms have always had this ability under the Sarbanes-Oxley Act, but the SEC lacked a formal appeals process. (Indeed, the June 28 Supreme Court decision, which affirmed the constitutionality of the PCAOB, arose out of a small accounting firm’s dissatisfaction with its 2004 inspection report.)

A key feature of the process is secrecy. If an accounting firm appeals to the SEC, the PCAOB will be prohibited from making disputed portions of its inspection report public until the commission completes its review, which could take anywhere from 30 days to over 100 days. Moreover, the SEC could decide to keep the information permanently private if its reviewers determine that the PCAOB’s findings were “arbitrary and capricious.”

Meanwhile, the public will learn nothing about the appeals process or the issues under contention, which will further cloud the results of PCAOB inspections for the accounting firms’ corporate clients who read them. “Until now, the SEC has not restricted the transparency of inspection reports pending the opportunity to seek review,” a PCAOB spokesman tells CFO.

So let’s get this straight – if an accounting firm takes issue with anything in the PCAOB’s report, the firm can then run crying to the SEC – which makes that portion of the report secret – and then the report will sit dormant until that portion reads to their liking which can take 30 to 100 days? OH! And on top of that, if the SEC finds something to be ‘arbitrary and capricious’ that issue will never see the light of day?

It’s not like these inspection reports are being issued at a rapid clip (PwC’s and KPMG’s reports for ’09 are still MIA) or filled with details that are actually meaningful to regular folks (e.g. the clients inspected) and now the SEC is going to let the firms write their own inspection reports.

So much for that small matter of “Oversight.” At least the SEC is being (somewhat) transparent about a power grab.

Auditors Can More Easily Dispute PCAOB Findings [CFO]

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

Deloitte Manages to Tone Down Its Response to This Year’s PCAOB Inspection Report

The PCAOB has released its 2009 Inspection Report for Deloitte and out of 73 audits inspected, 15 deficiencies were cited in this year’s review.

The Board writes that deficiencies are “failures by the Firm to identify or appropriately address errors in the issuer’s application of GAAP, including, in some cases, erikely to be material to the issuer’s financial statements. In addition, the deficiencies included failures by the Firm to perform, or to perform sufficiently, certain necessary audit procedures.”


Issues cited by the PCAOB in the report included goodwill impairment, deferred tax assets, inventory valuation, a failure to identify a “departure from GAAP,” among others. The Big 4 Blog rightly notes that this is the first time that the PCAOB has provided the sample size of the inspections which allows for some surprising error rates:

The error rate in this situation is quite high, almost one of every five audits has errors. Obviously, Deloitte performs thousands of audit each year and extrapolating from a small sample is quite dangerous, nonetheless, even at half of 20%, the natural conclusion is that one in ten audits has an error, and would have gone unnoticed had not the PCAOB done a good post-audit on the audit.

You could really make a fuss about what auditors did and did not do but the fact remains, audits are never perfect. Some are just more unperfect than others. What’s especially interesting is how Deloitte’s attitude has changed with regards to the PCAOB’s findings as compared to last year.

In last year’s inspection report, the Board cited seven audit deficiencies which resulted in a three page letter from Deloitte that, in no uncertain terms, told the PCAOB to get bent and keep their Monday Morning QBing to themselves. This was about as an aggressive of a response from an accounting firm as we had seen so it was definitely a surprise to see a firm lose their cool.

This year, despite the fact that Deloitte was cited for over twice as many deficiencies, the firm is considerably less defensive (read: boring) and put together a concise one page response to the Board’s findings that included the following:

“We have evaluated the matters identified by the Board’s inspection team for each of the Issuer audits described in Part I of the Draft Report and have taken actions as appropriate in accordance with D&T’s policies and PCAOB standards.”

It’s nice to see the firm playing nice with their regulator this year but we’re curious as to how the change in attitude came about. We hope that at least one of the remaining Big 4 will include a little more color in their response.

PCAOB_2010_Deloitte_Touche_LLP
PCAOB Inspection of Deloitte Audit – 20% Error Rate?? [Big 4 Blog]
Audit Deficiencies at Deloitte [WSJ]