Second guessing

PCAOB Publishes Part II of Deloitte’s 2008 Inspection Report, First Ever for a Big 4 Firm

They really, really, really don’t appreciate it when you blow off their recommendations. Here’s the statement from the Board:

The Public Company Accounting Oversight Board, in anticipation of questions about the publication of previously nonpublic portions of its May 19, 2008 inspection report on Deloitte & Touche LLP, issued the following statement today:

“The quality control remediation process is central to the Board’s efforts to cause firms to improve the quality of their audits and thereby better protect investors. The Board therefore takes very seriously the importance of firms making sufficient progress on quality control isn inspection report in the 12 months following the report. Particularly with the largest firms, which are inspected annually, the Board devotes considerable time and resources to critically evaluating whether the firm did in fact make sufficient progress in that period. The Board can and does make the relevant criticisms public when a firm has failed to do so.”

So to clarify, Deloitte had until May 19, 2009 to get their methods up to par but failed to do so. To put this into a little bit of context, Jim Doty was not yet the Chair of the PCAOB and Barry Salzberg was still the CEO of Deloitte’s U.S. firm. Does this mean that the PCAOB has been stepping up its game and this is the first instance of many to come? Hard to say but the audits that this inspection report cover are nearly five years old, so it’s debatable as to the value of Part II being made public now.

For Deloitte’s part, here’s current CEO Joe Echevarria’s statement:

“Deloitte is committed to the highest standards of audit quality and as newly elected CEO, it is my foremost priority. Our commitment extends from the top and cascades throughout our entire organization. We place great value on the PCAOB’s input and continue to work with the Board in support of our shared objectives. We recognize that audit quality is fundamental to protecting investors and ensuring the effective functioning of the capital markets.

“We have complete confidence in our professionals and the quality of our audits, and agree that there were and always will be areas where we can improve. In our drive for continuous improvement, we have been making a series of investments focused on strengthening and improving our practice, and will continue to do so to make Deloitte the standard for audit quality.”

In other words, a non-response response. However, it’s much more measured than Deloitte’s response to the initial release of the report. Their response letter spelled out their feelings quite clearly:

Professional judgments of reasonable and highly competent people may differ as to the nature and extent of necessary auditing procedures,conclusions reached and required documentation. We believe that reasonable judgments should not be second guessed and therefore disagree with a number of comments as indicated[.]

Deloitte’s letter is located Appendix C. You can read the full report, including all the details from Part II that were previously unpublished, on page 2.

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A Future McGladrey Associate Is Having Second Thoughts About Their Decision

Welcome to the your-day-can’t-be-worse-than-Julian-Assange’s edition of Accounting Career Emergencies. In today’s edition, a college student who accepted a fulltime gig with McGladrey is spooked after reading some kvetching about the firm on this here site. Did he make a bad choice?

Caught in a jam at work? Thinking about blowing the whistle? Concerned that the washrooms at your office aren’t sanitary? Email us at advice@goingconcern.com for lawyer recommendations or hand-washing tips.

Back to the morose McG soon-to-be:

I am a college student in the Southeast region of the United States. I am a graduate student and have accepted an offer to work full time at McGladrey (audit) in this region.

I have seen so many negative remarks on your website from comments and articles about the company, that I am somewhat concerned with my choice of firm. I seemed to fit in really well with the people at the office, and I enjoyed the office visit. I received offers from the other middle market companies (GT, BDO), but I felt best at McGladrey.

Seeing comments that compare McGladrey to McDonald’s is a bit disconcerting considering the fact that I have spent so much time and effort in college trying to gain a good job with security.

My ultimate question is, did I make a bad decision? Is McGladrey really THAT bad, or is it comparable to the other mid-tiers? To me, it seemed to meet the standard of the mid-tiers.

Please help me figure out if I need to try and make a move before I start.

Dear Unhappy Meal,

In case you haven’t noticed, the peanut gallery here at Going Concern is a cheeky bunch (love!) and your concern about the comments that you’ve read on various posts is a little overblown, in our opinion.

For starters, trust your instincts. You made the best decision based on your experience with the three firms you mentioned. Now, all of a sudden, you’re spooked because you read a few comments comparing McGladrey to McDonald’s? Have you read the comments on the Grant Thornton threads? They are, at the very least, on par with the spouting on the Mickey G posts.

Secondly, our most recent post about McGladrey was news of extra paid time off, concierge services, bonuses and babysitters. Babysitters! Does that sound like such a bad place to work? Yes, it’s the McG brass giving you the “we appreciate your hard work and this is our show of thanks” line and that always invites skeptical reactions but you show us one firm that doesn’t experience some backlash and we’ll show you firm that doesn’t exist.

So to answer more directly – you didn’t make a bad decision because you went with your gut. You made the best choice for you and not based on what you heard some anonymous commenter say. Go forth with confidence, grasshopper.

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.

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