KPMG Partner Doesn’t Understand Why People ‘Are Dropping Like Flies’

From the mailbag:

Hey Caleb,

Was with a [Midwest city] KPMG Advisory partner this weekend. She said that employees are dropping like flies because KPMG finally unveiled raises after 2 yrs without. Only EP’s were awarded (less than 5%). She said the numbers were in the double digits. What the hell did they expect?


If this sounds a little confusing, it was. We asked our tipster to clarify:

[A]re you saying that she’s under the impression that people are just now leaving because they are upset that they didn’t get raises for two years? And she’s surprised because the raises in the double digits when they were actually in the single digits?

And their response:

[S]he is surprised that so many are leaving especially given the unemployment rate in [midwest city] regardless of how long it’s been since raises were given. It’s not a secret that the other big four have not only given raises but as you report, awarded mid-yr bonus/raises as well.

We went back to some of this year’s KPMG comp threads and the 5% sounds a little suspect, as those rated as “exceptional” were pulling much better increases than that but then again, maybe there were some exceptions that weren’t reported. Also, it seems a little strange that a partner would be so clueless about raises but anything is possible, s’pose.

And as far as the gnashing of teeth because mid-year raises and bonuses are being handed out at other firms, keep in mind that KPMG isn’t even out of their first quarter yet. The rest of those firms have fiscal years that end prior to KPMG’s and they know how the first half of the year is shaping up. Expecting KPMG to start throwing money at people with less than three months in the books is a little ridiculous. At this point, the rumors around the idea of a mid-year surprise should keep you hopeful (but don’t go expecting anything).

It’s been no secret that people have exiting the House of Klynveld (and other firms) – regardless of the unemployment situation – prior to the end of the year (as is typical this time of year). Frankly, people we talk to are pretty optimistic about the job situation for most Big 4 types looking for something new, so this partner may be even more clueless than we thought.

Whatever the case, only 17 shopping days until those left will likely settle for sitting tight through another busy season. If we’re way off base here (or right on the money), feel free to jump in.

Big 4 Violin Virtuoso Needs Your Help Winning a Trip Down Under

Because we’re more or less a family here at Going Concern, when someone needs our help spreading the word about anything from compensation news to winning a ski getaway, we’re happy to help.

Today’s accountant-in-need is Larry Chou (a partner who was desperate for a pianist, basically challenged his entire office to step up to the plate and, ultimately, had his prayers answered.

ANYWAY, as you can see, Larry has bigger fish to fry. Here’s his audition:

He also passed along some instructions just so you can get this ball rolling:

How do I vote?

1) It only takes 5 seconds! Between December 10-17 (inclusive), please follow the link below to watch my video and vote for Larry Chou (lchou008). You may have to scroll halfway down the page to get to my video.

http://goo.gl/xxdZs

(Note: You do NOT need a Youtube user account to vote. Just follow the link!)

I’ve voted…now what?

2) Vote some more! The voting period extends from December 10-17, and you can vote once every day. That means you can vote 8 times if you remember to do it every day. This competition is on Eastern time, so each “voting day” on Pacific time technically runs from 9pm to 8:59pm of the following day. Additional votes from the same user on the same day are thrown out.

3) Check out my Facebook group page or my Facebook fan page.

4) Spread the word! I’m going to need every man, woman, and child to get in on this. Tell your friends, your family, your significant other, your co-workers, your classmates, your barber, your gardener, and your waiter/waitress! Just kidding (but not really, I’m going to need all the help I can get).

Thank you for your support!!

Well. What are you waiting for? ‘Tis the season to help other people out or something or other.

Can a Future Big 4 Associate Expect a Salary Adjustment When He Starts Work?

Welcome to the aren’t-you-glad-healthcare-reform-is-back-in-the-news? edition of Accounting Career Emergencies. In today’s edition, should an incoming associate expect a salary adjustment on day one or they doomed to a pittance?

Find yourself in a jam at work? Do you have eight hours to spare and aren’t sure how to best spend this rare free time? Wondering what you should get Sharon Allen for a retirement gift? Email us at advice@goingconcern.com and we’ll make sure you stay away from vacuum cleaners.

Returning to our Big 4 in waiting:

Can I expect to have my salary adjusted to market when I start employment? I will be starting in 2011. Reading through some of the articles and comments on here, it seems that new hires easily start with a salary above $50K. I received three offers from three Big 4 firms but all offered salaries were relatively far from $50K.

Each firm was within 1K-1.5K range from each other though. I know that starting salaries have even decreased in my area overall. I am not enjoying the thought of making less than what these firms have proven to have the potential to offer, or even making less than what another firm had to offer (although I knew that was the outcome by choosing this firm). I personally do not think it is worth asking for a raise or a salary adjustment since I feel that would only hurt my future annual raises. Should I just wait it out and see?

[Doubled over, catching breath, holding up hand with ‘I need a minute’]

Oh, dear. We had to take a break for a second, in fact our face hurts from laughing uncontrollably. Sorry about that.

Look friend, we don’t mean to make light of your question but a reality check is necessary here. There is virtually no chance that your firm will adjust to your salary when you start. You write, “I am not enjoying the thought of making less than what these firms have proven to have the potential to offer, or even making less than what another firm had to offer (although I knew that was the outcome by choosing this firm).”

We find this confusing for a couple of reasons – 1) obviously the Big 4 have “proven to have the potential” to pay more than $50k. It just happens this is occurring in a place where you don’t currently reside. If you did reside in one these places, your starting salary would eclipse the magical $50k. Were you expecting a big city salary for your mid-sized city lifestyle? 2) if you don’t like the idea of earning less money, why did you go with the firm that offered you less money? This simply doesn’t compute.

If making $50,000 is such a sticking point for you, move to a city with a higher cost of living so that you can eclipse the magic number you so desperately desire. If that’s not reasonable, then the best you can hope for is a pleasant surprise like PwC gave its recently hired peeps ($500 bonus for those hired post-June 30, 2010).

This may sound crazy but don’t get too caught up in what your salary is at the beginning of your career. So, to answer your question – sit tight and start your career. It’s a little early to be bitching about being underpaid when you haven’t billed a single hour.

Survey: Young Accountants Think Big 4 Is Overrated

Most people choosing the art of debits and credits as a career path, likely had aspirations for working for one of the illustrious Big 4. Fame, prestige, working with only the finest accountants that Omaha Steaks can buy, are all par for the course. This has been accepted as truth for many years.

But now – if you can believe this – this truth is being called into question in the UK – a part of the world that you might not expect.

Accountancy Age reports that a recent survey has found that young accountants (less than three years experience) are not as hung up on working at a Big 4 firm:

Only 40% of accountants with less than three years’ experience surveyed by recruiter Marks Sattin said it was important to work for a big firm — compared to an average of 67% for all of the 450 accountants surveyed in practice and industry.

“We are entering a new era in financial services…in which candidates want to sell themselves not by reeling off lists of FTSE 100 clients, but on their experience on smaller accounts providing higher levels of responsibility,” said Laura Wilson, associate director of the professional services division at Marks Sattin.

Granted, this is the pulse of the UK but there’s always been a large firm vs. small firm debate and this a trend that makes its way to the States (if it hasn’t already).

The reason for young accountants’ attitude, it turns out, is that they don’t care if they are working on prestigious clients; they are looking for more expansive professional experience:

“Whether it’s true or not, candidates think they’ll be doing work that is more involved at an early stage in their careers by joining a smaller firm. The perception is counting against the Big Four because candidates think that smaller firms offer more variety and more autonomy – and candidates are increasingly willing to sacrifice exposure to the FTSE 100 to get it.”

According to one person quoted in the article, part of this is a generational attitude but we’re not convinced that’s entirely the case. Sure, Gen Y wants to have more responsibility as quickly as possible but it’s not as though the Big 4 are taking on the same number of new recruits each year. As a result, a competitive recruiting process has made smaller firms a very good option. Plus, news about layoffs and a slow climb up the corporate ladder at the largest firms might have some students looking for opportunities.

Make no mistake, working at a Big 4 firm will always be goal number one for a lot of students and young CPAs. Regardless of what any survey says, many still have ambitions to be a partner in one of the largest firms or to work in some of the world’s prestigious companies. But the more informed students and young professionals are about career options, the perceived need for Big 4 experience on your résumé will be less compulsory.

Young accountants shun Big Four firms [Accountancy Age]

(UPDATE) Grant Thornton Employees Prohibited From Accessing WikiLeaks, Even in Their Spare Time

~ Update includes email sent to all KPMG employees and further details on communication within PwC.

Confirming some chatter in last Friday’s post on the banishment of WikiLeaks at Deloitte, notification at Grant Thornton was sent out late on Friday.

So not even after a long, hard day doing Stephen Chipman’slowed to read catty messages between diplomats or war logs on your personal computer. What’s next? Firmwide emails instructing lonely accountants not to visit Fleshbot (NSFW)?

Personal time aside, judging by the conversation on the Deloitte post, it appears that KPMG has also communicated ‘no peeky at wiki’ but we haven’t seen the official communiqué. And since all the major firms have contracts with the Feds, we decided to call around to see find out the scoop. So far, a source at PwC did inform us that the WikiLeaks website is accessible but no official policy on accessing the site has been communicated to the firm at large.

[UPDATE: We have learned that PwC’s Washington Federal Practice did receive communication prohibiting access, downloading, etc. etc. to WikiLeaks, however, as we’ve updated above, a firm-wide communication was not sent.]

Messages with E&Y and KPMG were not immediately returned. If there has been official lines have been drawn in the cyber-sand, kindly email us with any communication.

Earlier:
What if Accounting Firms Had Their Own Version of WikiLeaks?

UPDATE: The message from KPMG, courtesy of the sagacious Judge Sven Erik Holmes:

Date:December 10, 2010
To:All KPMG Personnel
From: Sven Erik Holmes, Vice Chair, Legal and Compliance
Subject:Government Notice Regarding Web site Access

PLEASE DO NOT DELETE THIS E-MAIL WITHOUT READING

In response to the recent well-publicized release of government documents on the WikiLeaks Web site, the federal government has begun notifying its contractors regarding restrictions on accessing classified documents included in that release. As a provider of services to several federal agencies, KPMG is a federal government contractor and has begun receiving such notices from its federal agency clients. This e-mail contains important instructions regarding access to such classified information, which are applicable to all firm personnel.

KPMG personnel should not access information marked or labeled as classified (including material publicly available on the WikiLeaks Web site or other Web sites) using government or KPMG computers or other devices that access the Web (such as PDAs or Smartphones) as doing so risks placing material that is still classified on non-classified systems. This restriction does not limit employee or contractor access to nonclassified, publicly available news reports (and other nonclassified material) that in turn reference classified material, as opposed to the underlying classified material itself (whether or not in the public domain).

The government’s notices remind us that federal contractors are obligated to protect classified information pursuant to all applicable federal laws, and to use government information systems, whether classified or unclassified, appropriately. Unauthorized disclosures of classified documents (whether in print, on a blog, or on a Web site) do not alter the documents’ classified status or automatically result in declassification of the documents. To the contrary, classified information, whether or not already posted on public Web sites or disclosed to the media, remains classified, and must be treated as such by federal employees and contractors, until it is declassified by an appropriate U.S. government authority.

If you believe that you may have downloaded classified information to a government or KPMG computer or other device that accesses the Web (such as a PDA or Smartphone), please contact [a KPMG lawyer who will ask you a ton of questions and probably scold you] in OGC at [lawyer’sname]@kpmg.com.

KPMG personnel are also reminded that firm policy requires personnel to maintain the confidentiality of any information that they obtain from a client in connection with a client engagement. It is important that the confidentiality of any such information be maintained.

No WikiLeaks for Deloitte Peeps

Funny how slow TPTB were to react this (message is dated today). Assange isn’t even haunting our dreams any more. Nevertheless, NO. PEEKY. And if you’ve already taken a look, you need to report yourself, ASAP.

ALERT: New federal government guidance on accessing or downloading classified information

Published: 10-Dec-10

The following is a message from [redacted], chief quality officer.

In the wake of the recent WikiLeaks disclosures of U.S. classified information, the U.S. Office of Management & Budget (OMB) and the Department of Defense (DoD) published guidance that prohibits federal government employees and federal contractor personnel from accessing the WikiLeaks website to view or download classified information. As federal contractors, the Deloitte U.S. Firms and their professionals are obligated to protect the integrity of classified information.

This notice is designed to facilitate compliance with the OMB and DoD guidance. All personnel should note the following:

Despite the unauthorized public disclosure by WikiLeaks, the information disclosed retains its classified status. The decision to remove classified status must be rendered by a government classification authority. In short, the information remains classified in spite of any public disclosure.

The access or download of classified information could be determined to be a security violation that requires immediate remediation, including removal of such information from our systems. A security violation could pose risks to the operations of Deloitte’s Federal practice and could negatively affect our client service capabilities.

You should not attempt to access the classified information on the WikiLeaks website or any related website. If you previously visited the WikiLeaks site or any related website to view or download classified information, you should immediately report a “Federal DOS Incident” via 1 800 Deloitte (option 5).

If you possess a security clearance, keep in mind that you are personally obligated to uphold the requirements for appropriate handling and dissemination of classified information, as outlined in your respective Classified Information Non-Disclosure Statement.

If you have any questions, please send them by e-mail to [redacted: presumably someone inside Deloitte who is familiar with these sorts of things].

[redacted]
Chief Quality Officer
Deloitte LLP

What if Accounting Firms Had Their Own Version of WikiLeaks?

We were a little surprised to learn that both KPMG and PwC had brief mentions in the WikiLeaks cables, however it is far less surprising that they were quite humdrum and didn’t bring anything new to light.


From the Swiss site, inAte>Wikileaks published cable referenced 09MOSCOW3144, created December 30, 2009, classified as confidential and originating from U.S. Embassy in Moscow, on alleged pressure that the Russian government has exerted on PwC to disavow its “clean opinion” audits in the Yukos Oil, aided by the reported raids on PwC office in Russia and threats to recall Russian audit license of PwC, closing this market for the Firm.

[…]

Wikileaks also published (09LONDON2598, for official use only, originating from U.S. Embassy in London, created November 11, 2009) KPMG’s sceptical reaction on the Queen’s opening speech in Parliament on November 18, 2009, where Her Majesty sets out one of the priorities for new legislative session – to develop a new Financial Services Bill, requiring form systemically important banks to establish plans for recovery and resolution, that ensure banks’ financial continuity, later called by journalists “living wills”.

Like we said – meh.

Now, what happens within a Big 4 or other large accounting firm is rarely a matter of national security (Francine may disagree with us) but there’s little doubt that firm CEOs, partners and other notables have said things that would range from the slightly embarrassing to the absolutely mortifying. Consequently, reactions to those statements would also range widely from mere chuckles to ”OH NO YOU DI’INT!” Because our imagination has a tendency to run wild, we’ll dispel a few of our own scenarios that we imagine being in the Big 4/mid-tier version of WikiLeaks:

Prior to the unveiling, Bob Moritz emails Tim Ryan, “Between you and me, the new logo looks like a half-finished Lego™ project.”

• Barry Salzberg and Jim Quigley are known inside some Deloitte circles as “Team Propecia.”

• After the OT loss to Michigan State, John Veihmeyer is so upset that he sends an email to Henry Keizer stating, “THAT’S IT! NO RAISES THIS YEAR.” Keizer responds to JV, reminding him that ‘if that punk Jimmy Clausen had stuck around’ they wouldn’t be in this situation and he shouldn’t take it out on the firm’s employees.

• Emails between two Ernst & Young partners in Jericho, reveal that they’ve been hoarding the extra bathroom keys because they can’t stand asking the receptionist.

• Various Deloitte partners are quaking because it is common knowledge that Arnie and Annabel McClellan have an elaborate spreadsheet detailing their various fetishes.

• In numerous exchanges Stephen Chipman begs Ed Nusbaum to let him ‘drop this ridiculous accent’ just like Ross did on Friends.

• High-level executives at McGladrey considered putting ecstasy in the punch so people would be happier but ultimately decided against it (Phoenix/Vegas went their own way) because it would have resulted in too many accountants dancing for no apparent reason.

Jack Weisbaum = The Most Interesting Man in the World. (Just like several actual WikiLeaks, everyone knew this to be true but it was not discussed openly.)

Perhaps you have your own theories or documentation regarding other exchanges. Please share with the group at this time or email us.

Deloitte’s Sharon Allen Will Be Having a ‘Big Party’ to Celebrate Her Retirement

Sharon Allen has spent 38 years at Deloitte. Doing the math on that, it probably feels more like a millennia. Accordingly, Ms. Allen has decided to hang up her green dot and chillax in Pasadena (Q&A with Accounting Today and we’ve picked out some of the highlights, including yes, a par-tay.


For starters, Sharon is a closer!

It’s a good time to leave when you’re on a high. I feel very confident in future leadership and the direction of our organization, and I think it’s just absolutely the right time to turn the reins over to others and proudly watch them continue to lead the firm in a good direction.

There will be a retirement rager, natch.

I’m going to have a big party. Yes.

Retirement will involve quality time with the hubby (but not so much that he goes nuts) and leading the Village People.

First of all I plan to spend a lot more time with my husband, family and friends, but of course there will probably be a limit on how much togetherness he can stand.[…] I have already committed to becoming the chairman of the board of the national YMCA board, which is an organization I’ve been involved with for over 25 years. I’m sure I will find ways to keep productively busy.

In case you weren’t aware, she doesn’t have a Y chromosome.

I am proud of many firsts that are in front of the titles I have carried. I was fortunate to be the first woman to become an office managing partner, the first woman to become a regional managing partner, the first woman to be elected to the board at Deloitte, and that’s been some years ago now. But I have to say my proudest accomplishment, I believe, was to have been elected as the first independent chairman of Deloitte’s board of directors. We separated our chairman and CEO role and created a full-time independent executive chairman of the board. It is an elected position by our partners, and I was very proud to be elected to that role. I always say, “Oh, by the way, I’m a woman.” It’s a very important distinction for me.

She’s more like you than you think – she got passed up for a manager promotion because her supervisor was clueless!

[P]erhaps one of the most important challenges that I had as I was coming up through my career also turned out to be one of my best lessons. That was when I was about four years into the firm and I expected an early promotion to manager, and I was passed over for that promotion. Interestingly, as I walked into my supervisor’s office and clicked off all the reasons why I thought I should have had the promotion and had earned it, he kind of sat back in his chair and looked at me and said, “I didn’t even know you did all those things.”

What about this boys club mentality?

I do think that there still is an underrepresentation of women in senior leadership in business generally and certainly in the board room of corporate organizations today. I do believe that organizations need to examine how they are recruiting, how they assure women are proportionally given the best assignments.

You know, back in the day, we basically had to come to work in drag.

There is a very big difference between today’s women and women of my era when I started in the profession because, in those days, honestly, you almost had to pretend there were no differences. I came up in the business world of wearing a suit and a little bow tie and trying to dress like the men and, of course, fortunately, men and women both can acknowledge the difference and benefit from that.

Leave Sharon your well wishes (or food and entertainment requests) below and if you get invited to this party, email us the pictures.

Comp Watch ’10: KPMG Town Hall Results in More Questions Than Answers

After hearing that KPMG was following suit with a mid-year compensation surprise, we’ve now been tipped that any hope you had of seeing a little extra moolah has been crushed:

Last night was KPMG’s New York Office (NYO) townhall meeting. During this meeting, close to 2,000 NYO employees of the firm gathered in a hotel in Time Square to listen to a series of presentations from the CEO, COO and Office Managing Partner (OMP). During this four hour presentation, they covered an array of topics, including: compensation and benefits, technology, etc.

Depsite hearing that the firm will be allowing staff (associates and senior associates) have KPMG email access on their iPhone, Android or BlackBerry phones, no further details were provided about what they will be paying for, if anything.

They also announced that they were keeping up with the average regarding compensation, but made it a point to mention that with every average, someone must be below the average, hinting that we were that someone. After finding out that there will be no mid-year bonsues or raises, some left the meeting rather disappointed… at least there was free booze and food (like any other normal KPMG event).

But wait! This sounded a little weird to us since our sources on the original story were solid, so we checked in with another source who told us the message was simply non-committal, “They didn’t really confirm/deny what was going to happen with the mid-year stuff.”

So all this “Yes? No? Maybe so,” probably isn’t so helpful but that’s where things appear to stand.

Back to our original tipster, who is now hearing talk of next fall’s associates receiving a boost in their starting salaries:

Later that evening, however, many of the recent hires (new associates in 2010) were beginning to hear that the 2011 new hires (for next year) were already receiveing salary adjustments (upwards into the $60,000’s), in addition to their already higher starting salaries and sign-on bonuses.

So my question is: Does KPMG plan on compensating the new associates (that started in 2010) that did not receive a sign-on bonus this year, or perhaps have any plans to bring their salary closer towards the industry average?

Starting salaries have been consistently rising over the years and with increased competition among the firms for the best recruits, you can expect that to continue. Whether that results in adjustments for KPMG’s latest class of new associates remains to be seen, since a mid-year surprise is still uncertain. We should say, however, expecting more money after being on the job for 2-3 months is a little presumptuous. We understand the frustration but, seriously? You can barely open Excel at this point.

As you hear more regarding the mid-year compensation (or lack thereof) email us with the scoop.

Update on Censured Ernst & Young Manager

Just a brief follow-up on the manager who received the disciplinary action handed down by the PCAOB on Monday.

We attempted to reach Jacqueline Higgins late yesterday at her office number in Boston, however we discovered that when we were transferred to her extension we simply bounced back to reception, who needless to say, was very confused about that phenomenon. After attempting to page Ms. Higgins, only then did the receptionist learn and then relay to us that Ms. Higgins was no longer with the firm.

We checked with Ernst & Young spokesman Charlie Perkins on this development and he confirmed that Ms. Higgins “will be leaving the firm at the end of the year.”

And lest there still be any confusion due to the carefully worded E&Y statement, the partner and senior manager in question have been dismissed from the firm.

We’ll keep you updated if we hear more from inside at the firm or if further action is taken by the PCAOB.

KPMG Partner Who Missed $1.9 Billion Error Having No Problem Blaming Others

Apparently it’s auditor punishment Monday. Or Tuesday, if you’re Down Under:

A lead KPMG auditor who only learnt about a $1.9 billion [about USD $1.88 billion] error in his audit of Allco Finance Group through a report in BusinessDay was benched for nine months by the corporate regulator yesterday.


To be completely fair, it sounds like it may have been a tricky audit:

Christopher Whittingham, a KPMG partner, led a core team of 20 audit staff that signed an unqualified audit report on the notoriously complex accounts for Allco for the year ended June 30, 2007.

Or was it?

The error detected by BusinessDay involved the 2007 accounts classifying $1.9 billion in liabilities owed by Allco as non-current, telling investors they fell due more than a year later. The liabilities were, in fact, current liabilities, meaning they were due within the year. The amount of current liabilities is a significant issue for shareholders when considering whether a company can meet its debts when they fall due.

Whatever the case may be, Mr Whittingham shouldn’t sweat it too much:

[T]he Australian Securities and Investments Commission released an enforceable undertaking with Mr Whittingham, which included a nine-month suspension, a $10,000 fine and 10 hours of professional education.

Well, at least he’s taking responsibility for his mistake and isn’t pointing his finger at anyone else or making excuses, right?

Mr Whittingham said he had relied on managers for aspects of the audit, the error had no bearing on Allco’s collapse and he had reissued its accounts the day after he became aware of the error.

Oh.

Regulator suspends senior KPMG auditor [Sydney Morning Herald]

Earlier:
(UPDATE) PCAOB Gives Ernst & Young Manager the Charlie Rangel Treatment

(UPDATE 2) PCAOB Gives Ernst & Young Manager the Charlie Rangel Treatment

~ Update includes statement from Ernst & Young.

~Update 2 includes statement from Claudius Modesti, PCAOB Director of Enforcement and Investigations

Today in obscure accounting oversight board enforcement actions, an Ernst & Young Manager in the Boston office was censured by the PCAOB for repeated violations oy to Cooperate with Inspectors, and Auditing Standard No. 3 (“AS3”), Audit Documentation.


The violations occurred when 27 year-old Jacqueline Higgins “(1) added documents to the working papers without indicating the dates that documents were added to the working papers, the names of the persons preparing the additional documentation, and the reason for adding the documentation months after the documentation completion date; and (2) removed a document from the working
papers after the documentation completion date.”

The timeline goes like this: E&Y was given notice by the PCAOB that an inspection of the unknown company’s audit was being performed on March 30, 2010 and the partner, senior manager and manager on the engagement were given notice on March 31, 2010. The inspection fieldwork was set to begin on April 19, 2010.

On April 5th, the three Ernsters began preparing for the inspection and that’s when problems started cropping up which led to more trouble. The order has the details:

First, Respondent reported to the Engagement Partner and the Senior Manager that a “Review Procedures Memorandum” was missing from the external working papers. The Engagement Partner and the Senior Manager directed Respondent to create and print out the missing document, and to backdate the document to November 30, 2009. The Engagement Partner and the Senior Manager directed Respondent to backdate her sign-off on this working paper to November 30, 2009, and to add this document to the external working papers.

17. Second, Respondent reported to the Engagement Partner that the tie-out of the financial statements contained in the external working papers was performed upon a pre-final set of financial statements. The Engagement Partner directed Respondent to remove this document from the external working papers, and to replace it with a newly created document which tied-out the final financial statements, and which the Engagement Partner directed Respondent to backdate to November 2009.

18. Third, Respondent reported to the Engagement Partner that the Average Forward Foreign Currency Contracts Calculation (“A3a Working Paper”) was missing from the external working papers. The Engagement Partner directed Respondent to gather the missing document, backdate it to November 2009, and add it to the external working papers.

19. Finally, Respondent reported to the Senior Manager that three checklists were missing from the external working papers. The Senior Manager directed Respondent to assemble the missing checklists as a single document (“HH6.8 Working Paper”) and to backdate her sign-off on this working paper to November 2009. The Senior Manager directed Respondent to add the document to the external working papers. The Senior Manager and Respondent reported to the Engagement Partner the facts and circumstances related to the creation of the HH6.8 Working Paper, and the Engagement Partner took no steps to cause the document to be properly dated, or to have it removed from the external working papers.

So those are the wonky details. Where this particular story is most interesting (in our opinion) is that Ms Higgins was, prior to this little mishap, on the fast track. According to the order, she graduated in May of 2005 and started with E&Y in September. She was promoted to senior associate in October of 2007 and then promoted to manager in October of 2009. Now, perhaps she was an audit-savant or perhaps not but in just over four years, she was a manager, which is a much quicker pace than usual.

Granted, she was still under the supervision of the senior manager and partner on the engagement but a young manager nevertheless. Now, you might be asking yourself, “what about the senior manager and partner? Are they getting their wrists slapped?” Conventional wisdom tell us, “absofuckinglutely” but the PCAOB isn’t saying. We were told by a spokesperson that the Board cannot comment on any other action related to this case.

As far as what a censure by the PCAOB actually entails, we were told that “It is an official reprimand from the PCAOB.” Some might call it a wrist slap but we’re damn sure you don’t want that in your file when you’re 27 years old. The action also states that Ms. Higgins was removed from the engagement in July 2010 and “at that time Higgins ceased participating in issuer audit engagements.”

Messages with E&Y spokesperson Charles Perkins and A message left with an attorney for Ms. Higgins were not immediately returned.

Ernst & Young has issued the following statement:

Our firm policy clearly prohibits persons from supplementing audit workpapers in circumstances like those described in the disciplinary order. When we determined that firm policy had been violated, we put the three individuals involved on administrative leave and subsequently separated the partner and senior manager. We have advised the PCAOB of these facts and have cooperated fully with the PCAOB throughout its investigation of this matter.

Based on the above, you might conclude that more disciplinary action will be coming from the PCAOB but like we said, they’re not talking.

UPDATE 2 – circa 3:30 pm: Claudius Modesti, PCAOB Director of Enforcement and Investigations, explained the seemingly light punishment in an email to Going Concern:

As to the censure, under the facts and circumstances, the censure is appropriate given Higgins’ relatively junior position on the audit team and her overall role in the conduct. We also considered the fact that she settled the matter without requiring the Board to commence litigation, which would have been nonpublic as required by the Sarbanes-Oxley Act.”

It was then explained to us that the PCAOB has never explained a disciplinary action in this way: “We also considered the fact that she settled the matter without requiring the Board to commence litigation, which would have been nonpublic as required by the Sarbanes-Oxley Act.”

If that’s not quite clear, consider this: It is significant because, had Ms Higgins acted in the alternative (i.e. not settled), litigation would have been necessary and no one outside of the PCAOB, Higgins, her lawyers and E&Y would have known about the proceedings. Granted, it’s fairly common for lighter disciplinary action to result from a settlement but it also makes sense from a PR perspective (not to mention, transparency and investor protection) if the PCAOB can actually announce that they are taking action against people who break the rules. Part of the challenge the Board has faced is convincing anyone that they have teeth.

It will be interesting now to see if the senior manager and partner follow the same track as Ms. Higgins and how the PCAOB will respond to their cooperation (or lack thereof).

Jacqueline a Higgins CPA[1]