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The PCAOB’s 2013 enforcement program – a 2014 update

Fried Frank Harris Shriver & Jacobson LLP

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USA April 7 2014

In January 2012, as the ten-year anniversary of the creation of the Public Company Accounting Oversight Board (the ―PCAOB‖ or ―Board‖) under the Sarbanes-Oxley Act of 2002 (―Sarbanes-Oxley‖) was approaching, we stepped back and reviewed the initial decade of the Board’s enforcement program.1 This article provides our annual review of the PCAOB’s enforcement program over the prior year, as reflected in Board proceedings made public in 2013. Our update focuses on PCAOB proceedings ―made public‖ during 2013, because Sarbanes-Oxley restricts the Board’s ability to publicize enforcement actions against registered public accounting firms or their associated persons.  In particular, Sarbanes-Oxley and Board rules prohibit the PCAOB from announcing or making its enforcement proceedings public until (1) the parties consent to a public hearing (which rarely occurs);

2

(2) the Board has imposed sanctions and the time to file an appeal with the 

Securities and Exchange  Commission (the ―SEC‖ or ―Commission‖) has expired;

3

or (3) the SEC, on 

appeal, issues an order regarding the sanctions imposed.

4

In 2013, the PCAOB continued to express frustration with its inability to make its enforcement 

proceedings public, with Board  Member Jeannette Franzel arguing that the current process is ―not 

sufficiently informative to investors, audit committees, auditors, or others interested in understanding audit 

risks and challenges.‖

5

    She further asserted that existing restrictions ―provide[ ] an incentive for 

respondents to litigate matters regardless of whether they believe they ultimately will prevail, in order to 

delay public disclosure.‖  Even so, the Board has been unable to persuade Congress to amend 

Sarbanes-Oxley to eliminate the existing confidentiality requirements.

As a result, the Board can only provide general information regarding its current inventory of non-public 

enforcement investigations and contested matters.  For example, the PCAOB stated last year that it had 

23 contested proceedings pending as of December 31, 2012 against registered public accounting firms 

and individual auditors, but could not publicly disclose the specific allegations.

6

   Board Member Franzel 

also stated in July 2013 that the Board had approximately 90 informal inquiries, formal investigations and 

non-public litigated proceedings currently in process.

7

    In contrast, the PCAOB made public 17 

enforcement proceedings in 2013, an increase from 11 in 2012.  They include 13 proceedings that were 

settled with the consent of the parties, and four adjudicated cases where the respondents had exhausted 

their right to file further appeals or the time for the respondents to file additional appeals had expired.

While the 17 enforcement proceedings made public by the PCAOB in 2013 provide an imperfect window 

into the Board’s enforcement program, they nevertheless offer valuable insight into the PCAOB’s recent 

priorities.  They include:

 Several proceedings alleging that registered firms or their personnel had improperly interfered 

with Board inspections or investigations, most notably by taking steps to modify or backdate audit 

workpapers;

 A number of cases alleging violations of basic auditing standards, including several proceedings 

in which the Board determined that  the failures were so severe as to warrant findings that the 

auditors had engaged in fraud, in violation of Section 10(b) of the Securities Exchange Act of 

1934 (the ―Exchange Act‖);

 A case in which the PCAOB alleged that a ―Big Four‖ accounting firm had improperly allowed a 

former partner to consult with engagement teams assigned to audits of the firm’s public company 

clients, while that partner was subject to a one-year suspension from association with a PCAOBregistered firm;

 Several proceedings alleging  violations of auditor independence requirements, including the 

performance of prohibited internal audit outsourcing services and a failure to comply with rules 

that require the mandatory rotation of the lead audit partner on a public company engagement; 

and

 Several proceedings that serve as a reminder that the PCAOB may bring enforcement actions 

against registered firms that fail to pay their annual PCAOB support fees or file annual reports 

with the Board on a timely basis.

The most notable features of the PCAOB’s 2013 public enforcement proceedings are described below.  

Taken as a whole, the proceedings suggest that most PCAOB enforcement actions involve serious and 

repeated failures, often by smaller firms with limited public company experience, to comply  with the Board’s auditing standards and other requirements, while the most severe financial penalties are imposed 

in cases involving larger firms.

8

Notable Features of PCAOB Enforcement Proceedings Announced in 2013

Interference with Board Inspections and Investigations

As part of the Board’s initial standard-setting activities, the PCAOB adopted enhanced audit 

documentation standards in 2004.  These standards  – now contained in AS 3  – require engagement 

teams to document their audit procedures within 45 days of authorizing a client to make use of an audit 

report in a required SEC filing, retain such documentation for a seven-year period, and carefully note any 

subsequent additions to, or modifications of, their documentation.

9

   Although this standard has now been 

in effect for almost a decade, the PCAOB continues to identify instances in which firms or auditors fail to 

comply with these requirements, and then seek to cover up the deficiencies by backdating or modifying 

audit workpapers in the face of a Board inspection or enforcement inquiry.

The PCAOB views the submission of altered or backdated audit documentation to the Board as a threat 

to the integrity of its processes, and has aggressively pursued cases against firms or individual CPAs who 

have sought to cover up a failure to perform or document required audit procedures.  Specifically, there 

were seven proceedings made public in 2013 – more than one-third of the proceedings announced during 

the year – that included allegations that registered firms or auditors had improperly backdated or modified 

audit workpapers.

10

Of the cases finding such misconduct made public in 2013, the most egregious fact pattern included 

allegations that the respondents, who were associated with two PCAOB-registered firms, coordinated the 

backdating of workpapers for the 2007 audits of three clients at a ―firm retreat,‖ after learning of an 

upcoming PCAOB inspection of one of the firms.

11

    According to the Board, the respondents then 

proceeded to backdate and sign workpapers that purported to document audit procedures that had not 

been performed, added a handwritten list of supplemental audit procedures to the workpapers, and prepared and backdated letters required under PCAOB rules confirming the firm’s independence from two 

of the three clients.  These materials, in turn, were subsequently provided to the Board’s Inspection Staff 

by the respondents,  without acknowledging that the materials had been backdated.  Following an

investigation by the Enforcement Division, the Board permanently revoked the registration of the two firms 

with the PCAOB and permanently barred two individuals who had participated in the backdating from 

association with a PCAOB-registered firm.  The Board also ordered one of the individuals to pay a 

$50,000 civil penalty.

In addition to the  Gruber and  Lee proceedings, the PCAOB announced several other actions against 

registered firms and individual CPAs in 2013 that involved allegations of backdated or modified 

workpapers.  In two additional proceedings that involved PCAOB-registered firms, the Board revoked the 

firms’ registration, but authorized them to reapply in two and three years, respectively.

12

  The PCAOB also 

censured and imposed a $10,000 civil penalty on each firm.

13

  In the other matters announced in 2013 in 

which individual CPAs were charged, the auditors were barred from association with a PCAOB-registered 

firm, subject to the right to petition for reinstatement after periods ranging from 18 months to three 

years.

14

With one exception, the backdating cases announced by the PCAOB in 2013 involved conduct by 

auditors associated with smaller accounting firms, rather than with ―Big Four‖ firms.  The exception was 

the Suddeth case, in which a former Deloitte & Touche LLP (―Deloitte‖) engagement partner—but not

Deloitte—was charged with backdating three workpapers relating to a 2010 audit.

15

   The Board’s Order 

noted that Deloitte had uncovered the improprieties on its own, investigated the matter, voluntarily selfreported to the PCAOB, and relieved Suddeth of any audit-related responsibilities prior to his retirement in 

2013.

Notably, the PCAOB announced the  Suddeth proceeding roughly five months after the Board had 

released a ―Policy Statement‖ addressing the circumstances under which the PCAOB may consider the 

extent of a firm or associated person’s cooperation in determining the outcome of a Board investigation.

16

In that Statement, the Board describes ―voluntary and timely‖ self-reporting, remedial or corrective action 

and/or substantial assistance to the Board’s investigative processes or to other law enforcement 

authorities as ―extraordinary cooperation‖ that may influence the PCAOB’s enforcement decisions.  The Suddeth case provides an example of a recent proceeding in which a registered firm’s self-reporting to 

the Board of violations of professional standards by an associated person may have favorably impacted 

the PCAOB’s assessment of the firm’s own conduct.

Significant Audit Deficiencies in Audits of U.S. and Foreign Issuers

During 2013, the Board announced several enforcement proceedings involving what the PCAOB viewed 

as serious failures to satisfy basic auditing requirements.

17

   These proceedings reflect:  (1) the Board’s 

continued focus on alleged audit deficiencies involving audits of foreign issuers; (2) cases in which the 

PCAOB alleged that the misconduct was so severe as to warrant findings that violations of the antifraud 

provisions of the Exchange Act had occurred; and (3) cases holding individual CPAs personally 

responsible for firms’ failures to implement adequate systems of quality controls.

Allegations Involving Audits of Foreign Issuers:  In 2013, the Board stated that its international program 

remains a ―key focus‖ for the PCAOB.

18

   It also reached a significant Memorandum of Understanding on 

cooperation with Chinese authorities last year.

19

   At the same time, the Board acknowledged that it still 

―face[s] challenges in this arena, including persistent obstacles to inspections and enforcement in some 

countries,‖ which the PCAOB avowed ―cannot continue indefinitely.‖

20

    Despite these limitations, the 

Board has sought to make its presence known in a number of matters involving audits of foreign issuers 

by PCAOB-registered firms based in the United States and abroad.

For example, in a settled proceeding announced in 2013, the PCAOB alleged that P. Parikh 

& Associates, a Mumbai-based firm registered with the Board, had committed ―numerous and repeated 

violations of PCAOB rules, quality control standards, and auditing standards‖ in connection with its audits 

of an SEC registrant based in New Delhi.

21

  The Board noted that the firm, which had 17 partners and 14 

offices (including seven offices outside India), had staffed the audits over a multi-year period with partners 

who lacked formal training in either U.S. GAAP or PCAOB auditing standards.  Finding the audits wholly 

deficient, the PCAOB revoked the firm’s registration, subject to the right to petition the Board to reapply 

for registration in two years.

The Board also announced two related enforcement actions in November 2013 that  involved multijurisdictional audits of foreign issuers.  These proceedings involved a U.S. accounting firm that had 

agreed to serve as the external auditor of  several issuers with their primary operations in the People’s 

Republic of China or Hong Kong, and then looked to a Chinese firm to perform a significant portion of the audit procedures for those registrants.

22

  As in the Parikh proceeding, the Board found that the accounting 

firm had taken inadequate steps to ensure that the  individuals conducting the audit procedures had 

adequate training in U.S. GAAP or PCAOB auditing standards.

23

   The Board also questioned the U.S. 

firm’s  capability to assume  final  responsibility for audits of China-based companies, noting that the 

individual at the firm assigned such final responsibility did not speak, understand or read Chinese, and 

instead ―relied on lower level accounting assistants with Chinese language skills‖ to review documents 

and engage in critical communications with client management.   The  Acquavella and  Svoboda

proceedings underscore that PCAOB-registered firms must take steps to satisfy themselves that they 

either possess or have ready access to necessary resources, before agreeing to serve as the auditors of 

companies that are headquartered or have significant operations in foreign jurisdictions with which they 

may have limited experience.

24

Findings of Section 10(b) Violations:  Securities practitioners typically  look to the SEC and the federal 

courts, rather than to the PCAOB, to define the scope of auditor liability under Section 10(b) of the 

Exchange Act and Rule 10b-5.  Both Sarbanes-Oxley and the Board’s rules provide, however, that the 

PCAOB may investigate and sanction registered firms and associated persons found to have violated 

provisions of the federal securities laws that relate to the ―preparation and issuance of audit reports.‖

25

  

The Board relied upon this authority in several 2013 proceedings in which the PCAOB found that firms or 

their associated persons had violated Section 10(b) and Rule 10b-5.

According to the PCAOB, an auditor violates Section 10(b) and Rule 10b-5 ―by issuing an audit report 

stating that the audit has been performed in accordance with PCAOB standards when he or she knows, 

or is reckless in not knowing, that the statement is false.‖

26

  In practice, it appears that the Board seeks to 

apply a standard analogous to that articulated by the Southern District of New York in  SEC v. Price 

Waterhouse.

27

    In that leading decision, Judge Sprizzo held that, to establish that an auditor violated 

Section 10(b), the SEC ―must prove that the accounting practices were so deficient that the audit 

amounted to no audit at all * * * or  an egregious refusal to see the obvious,  or to investigate the 

doubtful, * * * or that the accounting judgments  which were  made were such that no reasonable 

accountant would have made the same decisions if confronted with the same facts.‖

28 Specifically, in the proceedings made public in 2013 in which the Board alleged Section 10(b) and Rule 

10b-5 violations, the PCAOB emphasized that there were intentional or reckless failures by auditors to 

perform basic audit procedures that any reasonable accountant would have understood were necessary.  

In one case, the Board found that a registered firm had issued an audit report that falsely stated that a 

client’s 2006 and 2007 audits had been performed in accordance with PCAOB standards, when in fact 

the firm had not performed  any audit procedures before releasing its report.

29

    In another  2013  case 

where the Board found that a registered firm had violated the antifraud provisions, the PCAOB alleged 

that the firm either knew, or was reckless in not knowing, that ―few substantive audit procedures were 

performed‖ before the issuance of audit reports for three registrants.

30

    And, in a third case involving 

alleged Section 10(b) and Rule 10b-5 violations, the Board found that, among other things, the 

respondents had issued reports on an issuer’s internal controls over financial reporting (―ICFR‖) without 

familiarizing themselves with the relevant PCAOB auditing standards or performing any required ICFR 

procedures,  and in other cases failed to  obtain engagement quality reviews required under PCAOB 

standards before issuing audit reports.

31

Findings that a firm or associated person violated the antifraud provisions of the Exchange Act carry 

particular weight, as they may be especially likely to trigger additional collateral consequences and 

disclosure obligations for the respondents.    While the cases announced by the Board in 2013 

demonstrate that the PCAOB does not regularly allege violations of antifraud provisions under the federal 

securities laws, they also show that the Board may do so if it identifies repeated failures to comply with 

basic requirements.

Imposition of Secondary Liability on Individuals for Firm Violations:  The most recent standard-setting 

agenda issued by the PCAOB’s Office of the Chief Auditor (―OCA‖) notes that the OCA expects to 

recommend that the Board issue a concept release in the second  half of 2014 discussing potential 

improvements to current quality control standards, including those addressing supervisory responsibilities 

within PCAOB-registered firms.

32

   In the interim, however, the Board has continued to cite violations of 

Rule 3502 (―Responsibility Not to Knowingly or Recklessly Contribute to Violations‖) in proceedings where 

it concluded that individual CPAs were responsible for their firms’ alleged failures to implement adequate 

quality control systems and procedures.

33 Three such proceedings were announced in 2013.  In the first, the Board found a Rule 3502 violation 

where a senior partner was responsible for designing, communicating and monitoring his firm’s system of 

quality  controls, yet was aware that firm personnel responsible for several public company  audit 

engagements lacked relevant training or experience conducting audits in accordance with PCAOB 

auditing standards.

34

  In the second proceeding, the PCAOB sanctioned the managing member of a small 

accounting firm in Florida, who also had overall responsibility at the firm for promoting compliance with 

Board standards, after engagement teams under his supervision had failed to perform required audit 

procedures to address fraud risks at their clients.

35

  And, in the third proceeding, the Board found that the 

sole audit partner at a small accounting firm had ―directly and substantially‖ contributed to his firm’s 

violation of AS 7 by permitting the firm to issue audit reports without previously having obtained an 

engagement quality review by another auditor who concurred in the engagement team’s conclusions.

36

  

The Rule 3502 violations alleged in these proceedings underscore both the importance which the PCAOB 

attaches to firms’ systems of quality controls and the potential risk assumed by senior individuals at 

PCAOB-registered firms with quality control or risk management responsibilities.

Failure to Monitor the Post-Suspension Activities of a Former Partner

In the only 2013 proceeding in which a ―Big Four‖ firm was named as a respondent, the PCAOB 

sanctioned Deloitte for allowing a former partner who was subject to a bar on association with a PCAOBregistered firm to participate in various consultations with Deloitte audit teams working on public company 

engagements.

37

    This proceeding raises important issues as to what it means to be an ―associated 

person‖ of a registered public accounting firm, as well as what steps firms need to take when one of their 

partners or employees becomes subject to a Board suspension.

The 2013 case arose as a result of a prior Board action in 2008, in which the PCAOB had barred Deloitte 

partner Christopher Anderson from association with a PCAOB-registered firm, with a right to petition the 

Board for reinstatement in one year.

38

    In anticipation of the Board’s sanction, Deloitte restructured 

Anderson’s responsibilities at the firm, and Anderson also stepped down as a Deloitte partner and 

became a salaried employee of the firm.  These steps were apparently taken with the goal of ensuring 

that Anderson’s post-suspension activities at Deloitte would not cause him to remain an ―associated 

person‖ of the firm under the Board’s rules or run afoul of the 2008 Order.

39

  Moreover, Deloitte had some 

discussions with the PCAOB’s Staff regarding its plan to retain Anderson as a salaried employee during 

the term of his Board-ordered suspension. 

Nevertheless, the Board found that Deloitte violated Section 105 of Sarbanes-Oxley and PCAOB Rule 

5301 by allowing Anderson to work in a National Office position in Deloitte’s Audit and Assurance 

Services Group, which handled consultations with engagement teams and developed firm-wide audit 

policies and guidance.  Deloitte affirmatively restricted Anderson’s activities in numerous respects; for 

example, he was prohibited from signing audit reports for public company audit clients, accepting new 

public company audit engagements, or serving as a ―concurring reviewer‖ on such engagements.  

Instead, Deloitte’s intent apparently was that Anderson’s responsibilities would be limited to broader, firmwide topics, such as general audit guidance on the appropriate use of specialists by audit engagement 

teams.  According to the Board, however, Anderson consulted directly in his new National Office role with 

engagement teams assigned to the audits of three public company clients of the firm while still subject to 

the prior suspension.

In the Board’s opinion, such client-specific consultations were inconsistent with the 2008 Order, and a 

result of Deloitte’s  not having developed adequate procedures to define and monitor Anderson’s postsuspension activities at the firm.  As part of its settlement, Deloitte agreed to be censured and to pay a 

$2.0 million civil monetary penalty (tying the highest penalty ever assessed by the Board against a 

registered firm  in a settled proceeding).  In addition, Deloitte confirmed that it had adopted new 

procedures, including an undertaking to communicate the job responsibilities of  Board-restricted 

individuals ―to the PCAOB staff in advance of or contemporaneously with the  term of any suspension.‖  

Accordingly, the Deloitte case indicates that firms can retain valued professionals who become subject to 

PCAOB suspensions, but that they must monitor their activities (and may wish to pre-clear the scope of 

their activities during the suspension period with the PCAOB’s Staff).

Independence Violations

While the PCAOB launched no new standard-setting initiatives in 2013 relating to auditor independence, 

Chairman Doty questioned in a December 2013 speech whether the recent growth of accounting firms’ 

consulting practices may impact firms’ independence.

40

   Further signaling the Board’s continued interest 

in auditor independence, the PCAOB alleged violations of existing independence rules in two 

enforcement proceedings made public during 2013.

In the first proceeding, the Board found that a registered firm and one of its associated persons provided 

prohibited internal audit outsourcing services to an issuer, in violation of Section 10A(g) of the Exchange 

Act and PCAOB Rule 3520.

41

   In the second proceeding, the PCAOB found that a partner at a firm had 

served as the lead engagement partner on audits for two issuers for more than five consecutive years, in 

violation of the partner rotation requirements under SEC and PCAOB independence rules.   Accordingly, 

the Board held the partner and his firm responsible for violations of Exchange Act Section 10A(j) and Rule 

10A-2 thereunder, as well as for violations of Board rules.

42

   In both proceedings, the PCAOB imposed 

significant sanctions on the firms and individual partners, although the independence violations were not 

the sole basis for those sanctions. Failures to File Annual Reports and Pay Annual Dues on Timely Basis

The PCAOB has been announcing several enforcement cases every year against registered public 

accounting firms that fail to file annual reports, or pay required annual support fees, on a timely basis.  

2013 was no exception.  In two of the four cases involving such allegations made public in 2013, the 

Board settled with the delinquent firms, each of which paid the overdue fees, filed the overdue annual 

reports, and filed Form 1-WDs with the PCAOB seeking to withdraw their registration with the Board.  The 

two firms also agreed to a censure and the imposition of modest fines.

43

In comparison, the other two cases made public in 2013 were adjudicated proceedings.  They are notable 

primarily because they indicate how the relief sought by the PCAOB’s Enforcement Division may differ 

from the sanctions judged appropriate by a Hearing Officer.  In one of the proceedings, which involved a 

sole proprietorship, the Enforcement Division had sought a one-year suspension of the respondent’s 

registration with the Board, but the Hearing Officer found this sanction insufficient, in light of the repeated 

opportunities that the PCAOB had given him to comply with his obligations and avoid disciplinary 

sanctions.

44

    Instead, the Hearing Officer found that the respondent engaged in intentional or knowing 

misconduct, permanently revoked his registration with the Board, and imposed a $5,000 civil monetary 

penalty.

In the other adjudicated proceeding made public in 2013 involving a failure to file required annual reports 

or pay support fees, the Enforcement Division recommended a one-year suspension and a $7,500 

penalty.  The Hearing Officer agreed that the respondent had engaged in ―repeated instances of negligent 

conduct‖ and suspended the respondent for one year, as recommended by the Enforcement Division, but 

reduced the civil penalty to $2,500.

45

The respondents in these two adjudicated proceedings did not appeal the Hearing Officer’s decision to 

the full Board.   Had they done so, however, the Board also could have increased or reduced the 

sanctions recommended by the Hearing Officer, or decided to impose no sanctions at all.  The 

proceedings thus suggest that, depending upon the stakes and the findings made by a Hearing Officer, 

either or both parties to a contested Board proceeding – the respondent or the Enforcement Division  –

may have an incentive to pursue appeals to the full Board (and then possibly to the SEC as well). Conclusion

The number of enforcement proceedings announced by the PCAOB in 2013 increased over the 

number in 2012, and the Board has publicly stated that it currently has a large inventory of both 

investigations and contested proceedings in the pipeline.  A review of the proceedings made 

public in 2013 indicates that the PCAOB’s Enforcement Division is continuing to pursue a range 

of cases and also looking to further expand its reach, both substantively and territorially.  

Substantively, the Board’s expanded authority to regulate auditors of SEC-registered brokerdealers is likely to generate additional enforcement cases in the future.

46

    From a geographic 

standpoint, the Board’s continued focus on the qualifications and performance of U.S. firms 

auditing foreign issuers and its entrance into new cooperation agreements with foreign regulators 

also can be expected to give rise to additional investigations and enforcement proceedings.  At 

the same time, the Enforcement Division likely will continue to pursue ―bread-and-butter‖ cases 

involving, for example, situations where auditors interfere with Board inspections or investigations 

by backdating or altering audit workpapers or fail to  satisfy basic requirements under existing 

standards.

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