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	<title>Comments on: The Auditors&#8217; Chinese Wall &#8211; Is SOx Still A Keystone?</title>
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	<link>http://retheauditors.com/2009/02/20/the-auditors-chinese-wall-is-sox-still-a-keystone/</link>
	<description>The Business of the Big 4 Audit Firms</description>
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		<title>By: re: The Auditors &#187; Blog Archive &#187; @Going_Concern &#8220;Making Money The Old Fashioned Way: Exploiting IFRS Mandates&#8221;</title>
		<link>http://retheauditors.com/2009/02/20/the-auditors-chinese-wall-is-sox-still-a-keystone/comment-page-1/#comment-20949</link>
		<dc:creator>re: The Auditors &#187; Blog Archive &#187; @Going_Concern &#8220;Making Money The Old Fashioned Way: Exploiting IFRS Mandates&#8221;</dc:creator>
		<pubDate>Wed, 02 Sep 2009 21:44:33 +0000</pubDate>
		<guid isPermaLink="false">http://retheauditors.com/?p=1031#comment-20949</guid>
		<description>[...] firms are now exploiting the delays and confusion and, along with that, circumventing the stricter scope of service and independence rules enacted with Sarbanes-Oxley&#8230;       Easy AdSense by [...]</description>
		<content:encoded><![CDATA[<p>[...] firms are now exploiting the delays and confusion and, along with that, circumventing the stricter scope of service and independence rules enacted with Sarbanes-Oxley&#8230;       Easy AdSense by [...]</p>
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		<title>By: Training Software Cuts Down on Employee Training Costs &#124; Online Educational Resources</title>
		<link>http://retheauditors.com/2009/02/20/the-auditors-chinese-wall-is-sox-still-a-keystone/comment-page-1/#comment-2505</link>
		<dc:creator>Training Software Cuts Down on Employee Training Costs &#124; Online Educational Resources</dc:creator>
		<pubDate>Fri, 13 Mar 2009 03:19:30 +0000</pubDate>
		<guid isPermaLink="false">http://retheauditors.com/?p=1031#comment-2505</guid>
		<description>[...] The Auditor&#039;s Asiatic Wall - Is SOx Still A Keystone? [...]</description>
		<content:encoded><![CDATA[<p>[...] The Auditor&#8217;s Asiatic Wall &#8211; Is SOx Still A Keystone? [...]</p>
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		<title>By: Tenacious Truman</title>
		<link>http://retheauditors.com/2009/02/20/the-auditors-chinese-wall-is-sox-still-a-keystone/comment-page-1/#comment-2181</link>
		<dc:creator>Tenacious Truman</dc:creator>
		<pubDate>Fri, 27 Feb 2009 21:30:54 +0000</pubDate>
		<guid isPermaLink="false">http://retheauditors.com/?p=1031#comment-2181</guid>
		<description>CCollege,

I don&#039;t think I assumed anything that Wyman didn&#039;t explicitly write.  Wyman defined risk and I went with it.  He didn&#039;t discuss the trade-off between fees and risk -- which, by the way, was definitely what kept Andersen at Enron, year after year, even though it knew Enron was pushing the GAAP envelope.  They bet the firm for $100 million a year in Enron fees. 

 I agree with your point that the smaller clients were dropped from the portfolio(s) because the fees didn&#039;t justify the risks, in the minds of the partnership&#039;s lawyers.  We could probably write a book on all the risk mitigation missteps the firms take these days, from rubber stamped &quot;risk reviews&quot; (that nobody reads until after the client goes south when the search for the guilty parties is in full swing) to a relentless focus on reducing small risks to zero exposure while ignoring the huge &quot;elephant-in-the-room&quot; risks such as partner and staff qualifications (or lack thereof) for particular industries, clients and/or engagements.

With respect to your other points, I think if you go back and re-read Wyman&#039;s post, you&#039;ll see I was responding to his thoughts. For instance,  I did not suggest--indeed, I refuted--the idea that the large multi-nationals would &quot;jump ship&quot; to a mid-tier firm.  No offense to the mid-tiers, of course.

Have a great weekend!

-- Tenacious T.</description>
		<content:encoded><![CDATA[<p>CCollege,</p>
<p>I don&#8217;t think I assumed anything that Wyman didn&#8217;t explicitly write.  Wyman defined risk and I went with it.  He didn&#8217;t discuss the trade-off between fees and risk &#8212; which, by the way, was definitely what kept Andersen at Enron, year after year, even though it knew Enron was pushing the GAAP envelope.  They bet the firm for $100 million a year in Enron fees. </p>
<p> I agree with your point that the smaller clients were dropped from the portfolio(s) because the fees didn&#8217;t justify the risks, in the minds of the partnership&#8217;s lawyers.  We could probably write a book on all the risk mitigation missteps the firms take these days, from rubber stamped &#8220;risk reviews&#8221; (that nobody reads until after the client goes south when the search for the guilty parties is in full swing) to a relentless focus on reducing small risks to zero exposure while ignoring the huge &#8220;elephant-in-the-room&#8221; risks such as partner and staff qualifications (or lack thereof) for particular industries, clients and/or engagements.</p>
<p>With respect to your other points, I think if you go back and re-read Wyman&#8217;s post, you&#8217;ll see I was responding to his thoughts. For instance,  I did not suggest&#8211;indeed, I refuted&#8211;the idea that the large multi-nationals would &#8220;jump ship&#8221; to a mid-tier firm.  No offense to the mid-tiers, of course.</p>
<p>Have a great weekend!</p>
<p>&#8211; Tenacious T.</p>
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		<title>By: C College</title>
		<link>http://retheauditors.com/2009/02/20/the-auditors-chinese-wall-is-sox-still-a-keystone/comment-page-1/#comment-2178</link>
		<dc:creator>C College</dc:creator>
		<pubDate>Fri, 27 Feb 2009 18:09:37 +0000</pubDate>
		<guid isPermaLink="false">http://retheauditors.com/?p=1031#comment-2178</guid>
		<description>Tenacious,  

I think you made a bit of a leap by assuming that &quot;higher risk&quot; meant &quot;bigger, multimational&quot; companies.  &quot;Risk&quot; at a public accounting firm considers both risk of misstatement, and fees.  The level of risk a firm might accept for a $15 million client might not be accepted for a $500K client.  I think some of what happened is that the Big 4 looked at their $500K clients and said, &quot;we&#039;re not being paid enough to take on this risk, so we&#039;ll pull back on those jobs and focus on the $15M clients&quot;.  So the other Big 4 and 2nd-tier firms picked up the smaller jobs that were dropped.  

And of course, sometimes the $15M client is dropped, and those (at least to my knowledge, anecdotally) have mostly just been swapped among the Big 4.  I don&#039;t know of many huge multi-nationals jumping ship to BDO or GT.</description>
		<content:encoded><![CDATA[<p>Tenacious,  </p>
<p>I think you made a bit of a leap by assuming that &#8220;higher risk&#8221; meant &#8220;bigger, multimational&#8221; companies.  &#8220;Risk&#8221; at a public accounting firm considers both risk of misstatement, and fees.  The level of risk a firm might accept for a $15 million client might not be accepted for a $500K client.  I think some of what happened is that the Big 4 looked at their $500K clients and said, &#8220;we&#8217;re not being paid enough to take on this risk, so we&#8217;ll pull back on those jobs and focus on the $15M clients&#8221;.  So the other Big 4 and 2nd-tier firms picked up the smaller jobs that were dropped.  </p>
<p>And of course, sometimes the $15M client is dropped, and those (at least to my knowledge, anecdotally) have mostly just been swapped among the Big 4.  I don&#8217;t know of many huge multi-nationals jumping ship to BDO or GT.</p>
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		<title>By: Tenacious Truman</title>
		<link>http://retheauditors.com/2009/02/20/the-auditors-chinese-wall-is-sox-still-a-keystone/comment-page-1/#comment-2165</link>
		<dc:creator>Tenacious Truman</dc:creator>
		<pubDate>Thu, 26 Feb 2009 20:46:56 +0000</pubDate>
		<guid isPermaLink="false">http://retheauditors.com/?p=1031#comment-2165</guid>
		<description>Hi Wyman,

I&#039;m not stalking you, I swear.  But I can&#039;t let your comment go unchallenged.  (And I note that I&#039;m not making any new points here; Fran has posted on this before.)

You state that SOX forced &quot;the major accounting firms to look at their clients in terms of business risk&quot; and, based on the risk that a particular client might &quot;turn them into the next Andersen&quot;, to drop the riskier clients from their portfolio.  Those high-risk clients were picked-up by some of the mid-tier firms.  

Are you suggesting that the mid-tier firms are better positioned to manage the risks of those &quot;independence and poor control environment&quot; clients?  No offense to any mid-tier or smaller firms, but what makes you think they will do any better job of mitigating those risks than a Big 4 firm would have?  Haven&#039;t we already seen some of the same audit quality issues/failures at the mid-tiers?  And what&#039;s worse, those mid-tiers don&#039;t have the same financial or personnel resources to weather the storm as would one of the Big 4 (again, no offense meant).

So what I&#039;m saying is if any firm was too risky for, say, Deloitte, what makes you think that a BDO Seidman or Grant Thornton would or could handle that risk?

Competition may be a good thing and it may be true that any Big 4 firm who does a poor job may lose the account to one of the mid-tier firms, but isn&#039;t it also true that some companies, because of their sheer size and global dispersion, cannot be audited by any firm other than a Big 4 firm?  You wouldn&#039;t expect a local, regional firm to be auditing a multi-national corporation, would you?  If that&#039;s the true situation, then just how much force does the threat of competition have on the &quot;audit integrity and quality&quot;?  I would argue, &quot;not very much.&quot;

From my experience, auditors get changed because of (a) price, (b) chemistry between the audit partner and somebody with influence at the company, and (c) disagreement on accounting treatment.  (Those were ranked in descending order from most to least common, by the way.)  I have yet to see audit integrity and quality play a signficant role in the choice of auditor.  But maybe that&#039;s just me?

Best,

-- Tenacious T.</description>
		<content:encoded><![CDATA[<p>Hi Wyman,</p>
<p>I&#8217;m not stalking you, I swear.  But I can&#8217;t let your comment go unchallenged.  (And I note that I&#8217;m not making any new points here; Fran has posted on this before.)</p>
<p>You state that SOX forced &#8220;the major accounting firms to look at their clients in terms of business risk&#8221; and, based on the risk that a particular client might &#8220;turn them into the next Andersen&#8221;, to drop the riskier clients from their portfolio.  Those high-risk clients were picked-up by some of the mid-tier firms.  </p>
<p>Are you suggesting that the mid-tier firms are better positioned to manage the risks of those &#8220;independence and poor control environment&#8221; clients?  No offense to any mid-tier or smaller firms, but what makes you think they will do any better job of mitigating those risks than a Big 4 firm would have?  Haven&#8217;t we already seen some of the same audit quality issues/failures at the mid-tiers?  And what&#8217;s worse, those mid-tiers don&#8217;t have the same financial or personnel resources to weather the storm as would one of the Big 4 (again, no offense meant).</p>
<p>So what I&#8217;m saying is if any firm was too risky for, say, Deloitte, what makes you think that a BDO Seidman or Grant Thornton would or could handle that risk?</p>
<p>Competition may be a good thing and it may be true that any Big 4 firm who does a poor job may lose the account to one of the mid-tier firms, but isn&#8217;t it also true that some companies, because of their sheer size and global dispersion, cannot be audited by any firm other than a Big 4 firm?  You wouldn&#8217;t expect a local, regional firm to be auditing a multi-national corporation, would you?  If that&#8217;s the true situation, then just how much force does the threat of competition have on the &#8220;audit integrity and quality&#8221;?  I would argue, &#8220;not very much.&#8221;</p>
<p>From my experience, auditors get changed because of (a) price, (b) chemistry between the audit partner and somebody with influence at the company, and (c) disagreement on accounting treatment.  (Those were ranked in descending order from most to least common, by the way.)  I have yet to see audit integrity and quality play a signficant role in the choice of auditor.  But maybe that&#8217;s just me?</p>
<p>Best,</p>
<p>&#8211; Tenacious T.</p>
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		<title>By: Wyman</title>
		<link>http://retheauditors.com/2009/02/20/the-auditors-chinese-wall-is-sox-still-a-keystone/comment-page-1/#comment-2153</link>
		<dc:creator>Wyman</dc:creator>
		<pubDate>Thu, 26 Feb 2009 10:10:45 +0000</pubDate>
		<guid isPermaLink="false">http://retheauditors.com/?p=1031#comment-2153</guid>
		<description>One of the great things about SOX is that it really put pressure on the major accounting firms to look at their clients in terms of business risk.  Firm&#039;s began to look at their clients and wonder whether this company&#039;s relaxed control environment was going to turn them into the next Andersen.  What did we see following the Sarbanes Oxley Act.  The Big 4 began to drop some clients because of issues that included independence and poor conrtol environments.  This opened the door for some of these mid-level accounting firms like BDO and McGladrey to grow their market share and pick up some of these clients.  It is important that these other firms are in the mix.  The competition will act as its own control against poor audit integrity and quality because companies will begin to look at some of these other firms when they feel the auditors are not doing their job.</description>
		<content:encoded><![CDATA[<p>One of the great things about SOX is that it really put pressure on the major accounting firms to look at their clients in terms of business risk.  Firm&#8217;s began to look at their clients and wonder whether this company&#8217;s relaxed control environment was going to turn them into the next Andersen.  What did we see following the Sarbanes Oxley Act.  The Big 4 began to drop some clients because of issues that included independence and poor conrtol environments.  This opened the door for some of these mid-level accounting firms like BDO and McGladrey to grow their market share and pick up some of these clients.  It is important that these other firms are in the mix.  The competition will act as its own control against poor audit integrity and quality because companies will begin to look at some of these other firms when they feel the auditors are not doing their job.</p>
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		<title>By: C College</title>
		<link>http://retheauditors.com/2009/02/20/the-auditors-chinese-wall-is-sox-still-a-keystone/comment-page-1/#comment-2108</link>
		<dc:creator>C College</dc:creator>
		<pubDate>Mon, 23 Feb 2009 17:17:31 +0000</pubDate>
		<guid isPermaLink="false">http://retheauditors.com/?p=1031#comment-2108</guid>
		<description>Thank you Francine for a great entry.  It seems evident that allowing an external audit firm to perform internal audit functions would REDUCE overall risk.  Not to be too simplistic, but more time, more money, more hours invested... more ability to spot errors.  Additionally, external auditors are generally held to a higher standard than internal auditors, particularly in the area of regulatory oversight.  Seems to me that the Section 201-209 requirements highlight the difference between &quot;independent in fact&quot; -which an external auditor performing IA services can be- and &quot;independent in appearance&quot; - some interpret the dual roles as incompatible with each other.</description>
		<content:encoded><![CDATA[<p>Thank you Francine for a great entry.  It seems evident that allowing an external audit firm to perform internal audit functions would REDUCE overall risk.  Not to be too simplistic, but more time, more money, more hours invested&#8230; more ability to spot errors.  Additionally, external auditors are generally held to a higher standard than internal auditors, particularly in the area of regulatory oversight.  Seems to me that the Section 201-209 requirements highlight the difference between &#8220;independent in fact&#8221; -which an external auditor performing IA services can be- and &#8220;independent in appearance&#8221; &#8211; some interpret the dual roles as incompatible with each other.</p>
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		<title>By: Madoff &#187; The Auditor’s Chinese Wall - Is SOx Still A Keystone?</title>
		<link>http://retheauditors.com/2009/02/20/the-auditors-chinese-wall-is-sox-still-a-keystone/comment-page-1/#comment-2085</link>
		<dc:creator>Madoff &#187; The Auditor’s Chinese Wall - Is SOx Still A Keystone?</dc:creator>
		<pubDate>Fri, 20 Feb 2009 16:44:23 +0000</pubDate>
		<guid isPermaLink="false">http://retheauditors.com/?p=1031#comment-2085</guid>
		<description>[...] chartingstocks1 wrote an interesting post today on The Auditor&#226;</description>
		<content:encoded><![CDATA[<p>[...] chartingstocks1 wrote an interesting post today on The Auditor&acirc;</p>
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