Walking the Opportunistic Line – What Should the Big 4 Do About India?

The developing issues in India have been covered by Going Concern on a fairly regular basis, so I suppose I should take a crack at the subject as well.

It can be very easy scroll past the articles on India, but I advise you not to; after all, as one of the BRIC countries (do your homework), there is an absolute necessity for the Big 4 to position their resources here. And no, I’m not referring to outsourcing.


Based on February research, the Gold Men are bold to state the following:

While it’s clear that BRICs nations tightened their financial conditions when the financial crisis hit at the end of 2008, they rapidly eased back afterwards. Chinese and Indian financial conditions have eased substantially post-crisis, they’re now looser than pre-crisis even. Brazilian conditions also remain very stimulative compared to its past decade. Only Russia looks tight and unstimulative historically.

Sounds like a cash cow, doesn’t it? The BRIC development has long been looked at as the next fat cow for accounting firms to feed off of; closing the gap between the SOX hey days and the inevitable eventual IFRS transition. A fundamental issue is how the firms chase after business in these emerging markets. Push too hard and get burned. Tip toe through the daises and be passed by your three bullish cousins. Either way, on the table at all times is the branding image of each firm.

No one wants a Satyam situation on their hands, because even though no one knows what Satyam actually does, PwC’s global image is at stake because of this situation. Think about ripple effects. The potential client that is ignorant of the situation and whose thought process is “I think PwC is in some kind of trouble in India” is a more volatile problem than a client that, you know, reads the paper every day. Protecting the welfare of client relationships, but seeds and established, is absolute priority in situations like this.

With the exception of those few public sponsorships, the Big 4 don’t spend much time in the presses. And you know what? The big wigs like it that way. After all, we’re all accountants, forced to work in broom closets and wet basements for long hours and GREAT financial gain.

So the quieter the better, because we all know how it turned out for the last one to steal the spotlight.

Will CFO’s Audit Fee Benchmark Tool Help Keep the Big 4 Honest on Fees?

This story is republished from CFOZone, where you’ll find news, analysis and professional networking tools for finance executives.

There’s a bit of a tiff going on over at my former place of employment as a result of the cover story in the latest issue of CFO Magazine on the recent fall in auditor’s fees.

Some critics seem to fear that the phenomenon will be encouraged by a new benchmarking tool the website unveiled on April 1.

For a fee of $1,200, the tool allows companies to compare the fees that their peers pay for auditors. The process should be both quicker and more comprehensive than the requests for proposals now put out by many companies trying to figure out what they should be paying.


Accounting mavens David Albrecht and Lynn Turner, however, seem to worry that such an exercise will lead to the further commoditization of audits, and so to lower quality financial reporting, even though there’s no evidence the increased fees we saw in the wake of the Sarbanes Oxley Act did anything to improve its quality. Lehman Brothers, anyone?

Yet after the article appeared, Turner sent around comments on his list serve saying it contained several “factual inaccuracies” and that “a firm cannot do the same amount of work with these lower fees without seeing a huge reduction in profits.”

One problem here, it seems to me, is that we’re talking about an oligopoly, which invariably skews the normal effects of supply and demand. Albrecht concedes that the industry is an oligopoly but doesn’t make a cogent point about the significance of that. And he misses the other complication, which is that SarBox not only required auditors to review a company’s internal financial controls as well as its financial results, but also prevented auditors from offering audits as loss leaders for their more profitable consulting services. Now auditors can’t offer both services to the same clients. So audits have to stand on their own two feet.

Turner gets this point, though he confuses the chronology of the regulatory events involved. And he seems to suggest the article is flawed in the conclusion it draws about it, without saying how.

Here’s the point. If, in fact, the extra work SarBox required inflated auditors’ profits, why shouldn’t CFOs be able to make sure they’re getting what they pay for?

And the apparent assumption that benchmarking will inevitably lead companies to push for lower fees seems a bit shaky to me. As CFO.com’s editorial director Tim Reason points out, the process may instead merely keep auditors on their toes. Are Albrecht and Turner arguing that opacity is necessary for the public good, so auditors can pad their fees with impunity? Sorry, but that just doesn’t compute.

In an email to me this morning, Tim wrote: “We think finance executives and audit committees will benefit from having an independent, trusted editorial source provide them with a quick way to benchmark their fees-and make sure they are neither too high nor too low.”

Too low? Sure. You get what you pay for.

Tim also points out that there are no advertisers or sponsors for the tool. “It is a pure editorial offering being made directly to our readers, giving them information they’ve been asking us for years.”

Now there’s a radical idea.

Accounting News Roundup: ICAI Claims Big 4 Is ‘Bending Laws’; There Is No FASB, IRS Conspiracy; Aggressive IRS Blamed for More Americans Severing Ties | 04.06.10

‘Big four audit firms bending laws in India’ [Times of India]
A committee of the Institute of Chartered Accountants in India that is investigating the Satyam fraud is claiming that the Big 4 is “circumventing laws while providing auditing services in the country.” According to the Times of India, the committee has claimed that the firms have been granted permission to provide consulting services but not “taxation services, auditing, accounting and book keeping services and legal services.” The firms are able to provide these services through affiliate firms like Price Waterhouse Bangalore vis-à-vis Lovelock & Lewes who were responsible for the Satyam audit.

The committee states that “Indian firms and [multi-national accounting firms] are defacto the same entities providing the assurance, management and related services and as such their operations are designed to circumvent the provisions of the Chartered Accountants Act, 1949,” and that information sought from some local firms has not been provided to determine if they have partnered with the Big 4.


Debunking the FIN 48 Conspiracy Theory [CFO Blog]
When the IRS proposed its latest rule for disclosing uncertain tax provisions it debunked a theory concocted by some that the FASB was in cahoots with the Service to provide treasure maps for companies that take aggressive tax positions. It was thought that when the FASB was developing FIN 48 (aka Topic 740) in 2006 that they were siding with the IRS in requesting companies to report specific information about those positions.

Not the most interesting conspiracy theory we’ve ever heard but a conspiracy theory nonetheless. Anyhoo, FIN 48 requires less detail about the uncertain positions than the new IRS proposal, thus, debunking the conspiracy, at least in former FASB member Edward Trott, “I think FIN 48 accomplished exactly what was intended…The IRS’s proposed rule makes it clear that [FASB] was able to provide information to investors without providing a gold mine of information to the IRS.” You can go back to your illuminati theories now.

More Americans Give Up Citizenship As IRS Gets Aggressive Overseas [Dow Jones via TaxProf Blog]
Just over 500 people renounced their citizenship or permanent status in the fourth quarter of 2009. The report, citing public records, states the figure is more than all of 2007 and double of 2008. Mostly people are creeped out by future tax increases and more regulation, including the requirements to report details of foreign bank accounts.

While that does drive some people out of the US of A, the IRS claims that there has been a push to get some out who have already surrendered their passports, “The IRS says some of the swelling of numbers of expatriations towards the end of 2009 occurred because the agency made a push to notify people that had already surrendered their passport, but had not completed the process by submitting the IRS form. Until that form is received by the IRS, these people are still subject to U.S. tax.” Or in other words, “GTFO and stay out.”

Accounting News Roundup: Accounting for Healthcare Reform Begins; Should Small CPA Firms Partner with Large Firms on Projects?; Lawsuits Against Accounting Firms Rising Fast in UK | 03.28.10

The healthcare party is over – now comes the (accounting) hangover [FT Alphaville]
Now that healthcare reform is behind us, the matter of sorting out the impact on corporations now falls to the accounting professionals in those companies as the first quarter winds down this week.

FT Alphaville notes that AT&T, for one, has already filed an 8-K that states that it will “take a non-cash charge of approximately $1 billion in the first quarter of 2010 to reflect the impact of this change.” The change that the company is referring to is the “Medicare Part D subsidy” which, under the new law, is no longer eligible for a write-off against a company’s taxes. The subsidy is given to companies to help to pay prescription drug benefits to its employees.


FTA cites a report by Credit Suisse that shows many companies’ (including Goodyear Tire, International Paper and The New York Times) first quarter earnings will be impacted significantly by new healthcare legislation. And it also appears that it will cause companies to take a second look at the benefits they currently provide to employees, as Ma Bell stated in its filing that it “will be evaluating prospective changes to the active and retiree health care benefits offered by the company,” as a result of the legislation.

Why solos and small firms shouldn’t “partner” with larger CPA firms on projects [Fraud Files Blog]
Tracy Coenen recently had a large firm approach her to see if she’d be interested in helping them out with some “Fraud Risk Assessment services.”

The larger firm asked her if she would be interested in “a partner/subconsultant” arrangement. Tracy explains why this isn’t a good situation for solo practitioners like herself, “[T]he consulting firm doesn’t have the know-how necessary to provide their client with the services they need. But they’re not about to let something silly like competence stand in the way of collecting fees! They will find a way to do it.”

Tracy says that the larger firm will ask you to discount your billing rate, train their staff, and ultimately, give them the secrets to your practice, “Don’t lose money by discounting rates, training someone else’s staff for those discounted rates, and creating a competitor for yourself who uses your proprietary methodology.”

U.K. Accounting Suits Reached 5-Year High Last Year, Study Says [Bloomberg BusinessWeek]
The number of lawsuits filed in the UK against accounting firms in the past year is greater than the last five years combined according to Bloomberg. The thirteen suits filed in 2009 is more triple than the four suits filed in the previous five years. Although the number of suits is considerably smaller than the 61 suits filed after the collapse of Enron, et al. in the 2002-2003 time period, Jane Howard, a partner at Reynolds Porter Chamberlain LLP, is quoted that it’s not clear whether things are just getting started, “What is still hard to tell is whether this sudden rise in claims will subside quickly or whether accountants will face a higher number of claims over the coming years.”

The Recession Taught Some CFOs That They Need to Pay Closer Attention to Miserable Employees

Plenty of lessons came out of the financial crisis. For some it was that Big 4 auditors are irrelevant. For others it was that we need one set of high quality accounting standards ASAP. Aaaannnd for others, it was that the SEC needs to get better at pretty much everything.


For CFOs, it appears that at least some of them learned that miserable employees are a drag. Robert Half Management Resources surveyed 1,400 CFOs and 27% of them said “they learned to place greater focus on maintaining employee morale.”

It’s likely that this isn’t a lesson learned by just CFOs. Plenty of CPA firms have probably realized that a bunch of morose auditors and tax pros hanging around doesn’t make for a happy shop and are looking to improve their cheerleading skills going forward. KPMG has already brought back the Standing O, PwC, Ernst & Young, and Grant Thornton have all guaranteed merit increases for this year so there are signs that your happiness is no longer an afterthought.

CFOs Advise Keeping Employees Happy [Web CPA]

Big 4 Firms Are Planning for Your Exodus

For some time now, Caleb has been touching on the upcoming/ongoing/always-occurring exodus from Big 4 into the private sector. The obvious reasons for the change from public to private are obvious, but here’s a few for kicks:

• Bigger pay day (and potential growth)

• CPA requirements completed

• Actual work/life balance

&ill set transition to a new career

There are other reasons of course, but it is the ferocious combination of these that leads to the breaking point – low morale.


Going Concern received an email from a distraught and burnt out Big 4 auditor from the Southeast region:

The level of morale in the [XYZ] office is at an all time low. Discussion with low level staff, through managers, have yielded the same opinion of overwhelming expectations without the needed support from the firm. They want us to draw blood from a turnip, and they want it done better, faster, and with less resources than last year. This has caused everyone to start exploring options in the market. A vast majority have started fielding resumes and contacting recruiting firms. The select few who have made it past that hurdle are interviewing with no looking back.

Not to downplay what this auditor is saying (and I’m not), but this sounds like the unfortunate reality of many auditors working on smaller, non-public clients. You know, the not-as-sexy-as-ABC Bank but just as important to the firm’s bottom line. You won’t get tickets to the pro sport’s game, but thankyouverymuch for your efforts.

The reader goes on:

Primarily, people have expressed their interest in holding out any real intentions of leaving until promotions roll around in the later part of the summer. They’re hoping that maybe there will be some juicy 20% raise waiting for them, but the stark reality of a measly 5% raise is what they know is coming. Any fifth year Seniors who are waiting for the promotion to manager are just using it for resume purposes.

Our offices are already using under qualified second year staff at the Senior level, as well as retaining new managers in the Senior position because they are extremely understaffed at that level. This, in turn, is causing all of those people to take measures to leave perhaps after busy season and certainly after the insulting promotions come through in August.

It’s a matter of time before this individual (and half of their respective office) becomes another statistic that the Big 4 HR guru’s term “natural attrition.” From an HR perspective, here’s a loose idea of the attrition formula:

Fall 2010: 100 new hires

Fall ’11: 95 new hires become “2nd years”

Summer/Fall ’12: 88 2nd years promoted to senior staff, 70 seniors remain

Summer/Fall ’12: 2 years of public experience reached, 55 seniors remain

Summer/Fall ’13: 45 seniors remain

Summer/Fall ’14: 35 seniors remain

Summer/Fall ’15: 25 seniors remain; 15 promoted to manager, 10 remain on as seniors

Summer/Fall ‘XX: 10 senior managers are eligible for partner

The recession stunted this formula for every firm, as they were forced to make cuts, not only for cost cutting purposes, but also to keep their staffing formulas close to being in-check. But think about it – your firm expects this kind of turnover. They know it’s a matter of time before their hiring class is whittled down to 10% of its original size.

And in the case of the reader, their firm dropped the analytic ball 3-5 years ago. Had they better estimated the percentage of projected losses, there would be more seniors to handle the work.

Remember that time you felt bad about leaving? They’re waiting for you to do so.

Most Top Ten Accounting Firms Saw Lower Revenues, Headcount for 2009

Accounting Today put out their annual Top 100 Firms list late last week and while it focuses on the practices in United States it give us a little bit of room to speculate about who the real contenders are for the Global Six whathaveyou.

The ranking is based on net revenues from U.S. operations but it includes a lot data on each firm including # of offices, partners, total employees, and fee split.

Deloitte runs away with this list in three of the major categories – revenues, number of partners and total employees. The Casa de Salzberg had U.S. revenue of over $10.7 billion which was greater than #2 E&Y by over $3 billion.


Here are the top 10 firms along with their revenues, number of offices, number of partners and total employees

1. Deloitte – $10.7 billion; 102; 2,968; 42,367

2. Ernst & Young – $7.6 billion; 80; 2,500; 25,600

3. PricewaterhouseCoopers – $7.4 billion; 76; 2,235; 31,681

4. KPMG – $5 billion; 88; 1,847; 22,960

5. RSM McGladrey/McGladrey & Pullen – $1.5 billion; 93; 751; 7,755

6. Grant Thornton – $1.1 billion; 37; 535; 5,414

7. BDO – $620 million; 37; 273; 2,712

8. CBIZ/Mayer Hoffman McCann – $601 million; 180; 465; 4,580

9. Crowe Horwath – $508 million; 25; 240; 2,428

10. BKD – $393 million; 31; 258; 1,891

Some other interesting information from the list includes:

Declining Revenues – Revenues for all firms dropped with the exception of CBIZ/Mayer Hoffman McCann, Crowe Horwath and BKD. KPMG had the largest drop of nearly 11%.

Big 4 Dominate – The non-Big 4 firms’ combined revenue (approx. $4.7 billion) is still less than KPMG (smallest of the Big 4).

Personnel Changes – E&Y had a percentage increase in partners of 8.7% while total employees dropped nearly 6%. CBIZ/MHM saw a 32% increase in partners while total employees decreased over 12%. Only PwC and Crowe Horwath saw net increases in the number of partners and total employees.

Audit Heavy Firms – According to the list, PwC (52%), BDO (60%), Crowe Horwath (65%), and BKD (52%) all receive at least 50% of their revenues from audit fees.

So the whole Global Six thing, as much as we like to making a BFD out of it, is a non-issue. All the firms have global connections whether it’s through their own cooperative or through an international network so to cut it off at six seems a little clique-y. We’ll flip through the AT100 for any more interesting factoids but in the meantime feel to embellish any of the information presented here.

Top 100 Firms 2010 digital edition [Free registration for Digital Edition]

Has the Post-Busy Season Big 4 Exodus Already Started?

Seems a tad early but with two major deadlines passed, it’s possible that the Spring 2010 exodus may have started.

From one Big 4 auditor, “[A]pparently the DC and/or Philly office just underwent some serious turnover – my [schedule] just got all kinds of fucked up and my performance manager’s explanation was that “we’ve had some turnover and you have been shifted around as a solution.” So that’s cool. And by cool, I mean WTF because there was no warning, and it seems to be changing every few hours now.”


Our source continues:

Not a clue just how much turnover or if it was limited only to the audit practice, and how the turnover took place (I’m assuming people are quitting, as that is what pretty much all anyone at my level can talk about lately), but it was enough that I just went from two normal-hours clients to five “plan on overtime” clients. (It was six clients last night, but it looks like it got switched up again this morning.)

If there’s one thing that may cause violence more than someone quitting in the middle of busy season, it’s getting assigned to a “plan on overtime” client in the second half of March.

It’s likely that the timing of people leaving is an office by office phenomenon as one of our New York sources said that people aren’t leaving but “everyone wants to, but that’s nothing new.”

So if people are heading for the exits in your office, forced or otherwise, let us know.

Are Big 4 Auditors Irrelevant?

Okay people, the calls for the complete obliteration of the accounting world have begun. Check that. It’s more or less the accounting world as it relates to auditors of public companies (i.e. Big 4 auditors).

Steve Goldstein at MarketWatch, for one, is NOT A FAN, “What precise purpose does it serve to have a supposedly independent auditor (paid for by the company) sign off on accounts? From Enron to Lehman to Satyam to Parmalat, it’s clear that the major accountants lack either the skill or the determination (or both) to ferret out fraud.”


So in case you didn’t catch it, he’s calling into question the Big 4’s (our assumption) integrity, competence and fortitude. Oh and before you start huffing about “it’s not the job of the auditor to detect fraud,” we’d argue that’s not even the point any more. Lehman was engaging in what a former CFO calls “shenanigans” that E&Y knew about for years and went along with it. Why? Because Lehman said everything was kosh.

Goldstein goes on:

Company executives already are forced to sign off on their accounts. When they are caught lying, companies face liability over disclosure.

So the threats that keep (some) companies honest are there regardless of whether the reports are audited. The outside auditors themselves are assigned a negligible value by the market.

A solution? Here’s two admittedly out-there solutions that the Securities and Exchange Commission probably won’t adopt.

One is quite simple: get rid of accountants. Who cares? They add no value, and their expenses weigh on the bottom line.

The other would be for someone else to hire the accountant. How about the company’s top five shareholders? While the likes of Fidelity would grumble about the added costs and the free-rider benefit for smaller shareholders, they would certainly have an interest in securing a far tougher audit.

Okay, Big 4 auditors, here’s your homework: explain why auditing for public companies isn’t irrelevant. We’ll listen, we swear. Or just start shooting off at the mouth if you feel it necessary. Goldstein isn’t the first to make this determination. Francine McKenna and Jim Peterson have argued that the value of an auditor’s opinion has been nil for quite some time and they’re both Big 876454 alums. It’s okay if you admit it. Acceptance is the first step.

What exactly is the point of having accountants? [MarketWatch]

Why Isn’t Deloitte Ranked Higher on DiversityInc’s Top 50 List?

What a relief. We were really concerned that we would get half way through March without hearing about a list of companies being good at something that included the Big 4. Fortunately, DiversityInc comes to our rescue today with their list of Top 50 Companies for Diversity for 2010.

Aaaand as you might exall present and accounted for, although some firms may wish to be higher(?). How does one determine success on these lists? Just being on it? Making the top ten? Is it an honor just to participate in the survey?

Speaking of the survey, the website describes the methodology so you can get an idea of how this particular jumble falls together. The survey is broken down into four areas:


CEO Commitment

Human Capital

Corporate and Organizational Communications

Supplier Diversity

Digging further, we found more details:

The survey consists of more than 200 empirical questions (no subjective or qualitative information), which have predetermined weightings. Ratios between key factors, such as demographics of managers compared with managers who received promotions, play a significant factor in determining point scores. Companies must score above average in all four areas to earn a spot on the list. CEO Commitment is the most heavily weighted area because if a company lacks visible leadership, its diversity-management efforts will fail to be a priority.

SO! While this explains some things, it certainly brings up more questions. Since we spend the majority of our day perusing the web for every instance of Big 4 CEOs simply breaking wind, we’d like to think that any “CEO Commitment” as it relates to diversity would be noticed by us or our team of monkeys that work around the clock.

That being said, we’d be hard pressed to find a bigger diversity go-getter than Deloitte’s CEO Barry Salzberg. The man is tirelessly pursuing diversity at every waking moment. Even after Deloitte announced its freshly minted Chief Diversity Officer, Bar gave a speech earlier this week on as part of the DiversityInc festivities demonstrating that he’s still on this.

So then, our question is, how does Ernst & Young rank 5th, PwC 6th, KPMG 15th and Deloitte bring up the rear at 25th?

Perhaps the other firms display diversity fliers with their CEOs mugs on them to serve as constant reminder to all employees of the diversity in their firm but if CEO commitment is measured by MSM talking points, how does anyone beat Barry Salzberg? The only thing we can think of is there is some sort of secret anti-male pattern baldness bias at DiversityInc that quietly knocks Deloitte down the list. Sure Dennis Nally is slowly going Costanza there but Moritz in the tighty-whities probably made up for it.

So the efforts of Deloitte’s diversity commitment are rewarded but did they get the recognition they deserved?

The Unveiling of the 2010 DiversityInc Top 50 [DiversityInc]
The DiversityInc Top 50 Companies for Diversity [Full List]

Accounting News Roundup: CFOs, Staff Are Getting Worn Down by Guidance; Miami Forensic Accountant to Plead Guilty; Big 4 In Pari Delicto Defense Strategy | 03.10.10

A Growing Contagion: Accounting Fatigue Syndrome [CFO Blog]
Anyone getting worn out from all the guidance that is coming from the alphabet soup of regulators? You’re not alone and there appears to be an epidemic, something that CFO Blog has deemed “Accounting Fatigue Syndrome.” The long/short of it is that things are only going to get more complex as FASB and IASB continue to converge their rules and guidance continues to come out of both rule making bodies.

“Like many finance executives, Terry Lillis, CFO of Principal Financial Group, is tired. The constant stream of guidance from regulators and accounting standard-setters — plus the expected inflow of more to come over the next few years — has created “huge accounting fatigue” among his finance staff”


What’s the solution to AFS? How about just getting out of the biz altogether? “While the panelists gave no hope to CFOs who wish the standard-setters would either slow down or cut back on their agenda, they did offer one tip for ending accounting fatigue. ‘If I were a CFO, the first thing I would do is look at my early-retirement provisions,’ quipped J. Edward Grossman, a Crowe Horwath partner.”

High-profile Miami accountant Lew Freeman to plead guilty to fraud [Miami Herald]
A couple of weeks ago we told you about “go-to” forensic accountant turned swindler Lewis Freeman and his legal trouble.

Today he is expected to plead guilty in Miami to embezzling $2.6 million from his clients. Prosecutors have alleged that Freeman, “wrote 162 unauthorized checks to himself totaling about $6 million from the accounts of five failed businesses once under his company’s control, but put back about half of the money.” Freeman has been cooperating with investigators since his arrest but still may face 10 – 20 years in prison.

In Pari Delicto: Are Auditors Equally At Fault In The Big Fraud Cases? [Re: the Auditors]
Francine tackles PwC and KPMG’s defense strategy involving in pari delicto to avoid their roles in fraud cases.

The way I see it, the in pari delicto doctrine is being used like a pair of needle nosed pliers by audit firm defense lawyers to diffuse a bomb – huge liability for some of the biggest frauds in history. The in pari delicto doctrine attempts to pull the auditors’ tails from the fire by excusing any of their guilty acts due to the approval of those acts by potentially equally guilty executives.