Accounting and Auditing bodog casino Activity—2020 Review and Analysis

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Accounting and Auditing bodog casino Activity in 2020

The SEC initiated 50 bodog casino actions involving accounting and auditing allegations in 2020 against 36 individuals and 34 firms. Of the 50 bodog casino actions, only four accounting and auditing actions were civil actions, with the remaining initiated as administrative proceedings. In 2020, 71 respondents settled charges that the SEC had brought in 2020 and in prior years. Monetary settlements were imposed on 53 (75%) of those respondents and totaled approximately .4 billion. In 23 of the 71 settlements, the SEC reported that it took into account the respondent’s self-reporting, cooperation, and/or remedial efforts as it set penalties and other remedies.

The PCAOB publicly disclosed 13 bodog casino actions involving auditing in 2020, just over half of the 24 actions disclosed in 2019.1 Of the 26 individual and firm respondents that settled with the PCAOB in 2020, monetary settlements were imposed on 20 (77%). Monetary settlements totaled almost .5 million.

SEC bodog casino Involving Accounting and Auditing Declined in 2020
  • The total number of accounting and auditing bodog casino initiated by the SEC in 2020 declined 14% from 58 to 50. This was a 17% decrease from the average number of 60 initiated bodog casino in the 2015–2019 period.
  • During 2020, the bodog casino brought 46 (92%) administrative proceedings, with all but one announcing a concurrent settlement on the same day.
  • The SEC also brought four (8%) civil bodog casino. All but one of these civil bodog casino were resolved by the end of 2020.

SEC bodog casino involving accounting and auditing by year initiated 2015-2020

The Decrease in SEC bodog casino Resulted from a Substantial Decline in the First Quarter
  • The SEC initiated only three accounting and auditing bodog casino actions in Q1 2020, the lowest level of activity for any quarter from 2015 through 2020 and less than 20% of the average Q1 bodog casino level over the last five years.
  • bodog casino initiated in Q2 through Q4 of 2020 returned to the levels experienced in 2019.
  • More than half of the bodog casino in 2020 were initiated in Q3 (27), compared to one-third on average in Q3 of 2015–2019.

Quarterly SEC bodog casino involving accounting and auditing by year initiated 2015-2020

After the First Quarter, bodog casino Activity Recovered to 2019 Levels
  • Relative to Q1 2019, which was affected by the government shutdown for most of January, SEC bodog casino activity in Q1 2020 was particularly slow. The SEC did not initiate any actions in March 2020.
  • However, SEC bodog casino activity recovered in Q2 2020 as staff from the Division of bodog casino transitioned to a remote working environment.2
  • During the last week of Q3 2020, which marks the end of the SEC fiscal year, the SEC initiated 13 bodog casino. A similar uptick in initiated bodog casino also occurred at the end of Q3 2019.

SEC bodog casino involving accounting and auditing by date initiated 2019-2020

The Percentage of Non-U.S. bodog casino Brought by the SEC Was Consistent with Prior Years
  • The percentage of non-U.S. bodog casino brought by the SEC was lower in 2020 (14%) compared to 2019 (17%) but in line with the 2015–2019 average (14%).
  • Of the seven non-U.S. bodog casino, five (71%) bodog casino involved internal control over financial reporting and one action involved auditing allegations.
  • Since 2015, the SEC has brought bodog casino involving respondents in 24 countries outside the U.S. The most bodog casino (four each) have been brought against respondents in Brazil, Canada, India, Japan, Mexico, and the United Kingdom.

SEC bodog casino involving U.S. and non-U.S. respondents by year initiated 2015-2020

The Percentage of SEC bodog casino Involving Announced Restatements and/or Material Weaknesses in Internal Control Was Consistent with 2019
  • Of the 50 SEC bodog casino actions in 2020, 18 involved announced restatements and 11 involved announcements of material weaknesses in internal control.
  • The percentage of 2020 SEC bodog casino involving announced restatements and/or material weaknesses in internal control (40%) was higher than the 2015–2019 average (36%).
  • Of the 18 bodog casino involving restatements in 2020, 15 alleged improper revenue recognition.

SEC bodog casino involving announcements of restatements and/or internal control weakness by year initiated 2015-2020

Internal Control Over Financial Reporting and Revenue Recognition Were the Most Common Allegations in 2020 SEC bodog casino
  • Of the 50 bodog casino brought by the SEC in 2020, about one-third alleged revenue recognition violations and more than half alleged violations related to a company’s internal control over financial reporting.
  • Of the 12% of the bodog casino brought by the SEC that related to auditing, the majority involved allegations concerning audit documentation and/or supervision of the audit.
SEC bodog casino Involved Fewer Respondents in 2020
  • There were 70 total respondents in the bodog casino initiated by the SEC in 2020, 29% below the 2015–2019 average.
  • The number of individual respondents remained at the level in 2019, 43% below the average number of 63 respondents in the prior four years.
  • In 2020, 49% bodog casino respondents were firms, up from the 2015–2019 average of 43%.

Respondents in SEC accounting and auditing bodog casino by year initiated 2015-2020

The Majority of SEC bodog casino Involved SEC Registrants and Related Individuals
  • The number of SEC bodog casino involving SEC registrants and related individuals increased by 35% in 2020 to 58 from 43 bodog casino in 2019.
  • SEC bodog casino involving auditors and audit firms declined by 64% in 2020 to 12 from 33 bodog casino in 2019.
  • There were no bodog casino involving auditors or audit firms of broker-dealers in 2020.

Respondents in SEC bodog casino by year initiated 2015-2020

Total Monetary Settlements in 2020 SEC bodog casino Were Approximately .4 Billion
  • In addition to bars, suspensions, and other nonmonetary sanctions, the bodog casino imposed monetary settlements against 75% of the respondents for a total of approximately .4 billion.
  • Total monetary settlements against firms comprised the vast majority bodog casino .4 billion settlement total. Total monetary settlements against firms increased in 2020, but the median settlement decreased from .1 million in 2019 to .4 million in 2020. Two firms paid total monetary settlements of at least 0 million each in 2020.
  • Total monetary settlements against individuals were approximately .9 million, .8 million lower than in 2019. The median settlement increased from ,000 in 2019 to ,000 in 2020.

Monetary Settlements in Resolved SEC bodog casino 2018–2020 ($ amounts in thousands)

Disgorgement and Prejudgment Interest Comprised 63% of Total bodog casino Settlements
  • For firm respondents, disgorgement and civil penalties accounted for approximately 60% and 37% of all monetary settlements, respectively, while prejudgment interest accounted for the remaining 3%.
  • Some bodog casino largest disgorgement amounts were imposed after the U.S. Supreme Court decision in Liu v. bodog casino on June 22, 2020.3 In particular, 97% of the total disgorgement amount charged by the bodog casino in 2020 was imposed after the Liu decision.
  • For individual respondents, disgorgement and civil penalties accounted for approximately 13% and 86% of all monetary settlements, respectively, while prejudgment interest accounted for the remaining 1%.
  • In 23 settlements, the bodog casino reported that it took into account the respondent’s self-reporting, cooperation, and/or remedial efforts as it set penalties and other remedies. These mitigating factors were applied to 19 firm respondents and four individual respondents.4

Monetary settlements in SEC bodog casino by respondent type 2020

PCAOB bodog casino Activity Decreased to a Level Well Below Recent Years
  • As required by the Sarbanes-Oxley Act, the bodog casino keeps its investigations and disciplinary proceedings confidential and nonpublic until the matter is settled or otherwise finalized.5
  • PCAOB bodog casino actions decreased 46% in 2020 compared to 2019.
  • At 13, the number of PCAOB bodog casino in 2020 was 39% of the 2015–2019 average and was the lowest number of bodog casino disclosed in the last six years.
  • In 2020, for the second year in a row, the PCAOB did not disclose any bodog casino pertaining to audits of broker-dealers. In the prior four years, bodog casino involving auditors and audit firms of broker-dealers comprised nearly 30% of all bodog casino on average.

PCAOB bodog casino involving auditing by year finalized 2015-2020

PCAOB bodog casino Decreased Each Quarter of 2020 Compared to Each Respective Quarter in 2019
  • Unlike SEC bodog casino, finalized PCAOB bodog casino did not return to pre-pandemic levels after Q1 2020.
  • For each quarter in 2020, the number of finalized PCAOB bodog casino was equal to or lower than that for each respective quarter over at least the last three years.
  • Nearly 70% of 2020 PCAOB bodog casino involved alleged violations of the Engagement Quality Review (EQR) standard, up from a third of the bodog casino in 2019.
  • Two-thirds of the 2020 bodog casino involving firm respondents contained allegations related to the firm’s system of quality control, down from 77% in 2019.

Quarterly PCAOB bodog casino involving auditing by year finalized 2015-2020

Fewer PCAOB bodog casino Involved Non-U.S. Respondents
  • The percentage of PCAOB bodog casino involving non-U.S. respondents in 2020 (8%) decreased substantially compared to 2019 (29%) and the 2015–2019 average (25%).
  • The one non-U.S. action involved an audit firm and two auditors in Australia. Since 2015, the PCAOB has brought bodog casino involving respondents in 15 countries outside the U.S. The most bodog casino have been brought against auditors and audit firms in Brazil.

PCAOB bodog casino involving U.S. and non-U.S. respondents by year finalized 2015-2020

Nearly 40% of PCAOB bodog casino Involved Announced Restatements and/or Material Weaknesses in Internal Control
  • The proportion of PCAOB bodog casino in 2020 involving announced restatements and/or material weaknesses in internal control (38%) was more than double the 2015–2019 average (15%).
  • Unlike 2019, when the majority of PCAOB bodog casino with an announced restatement and/or material weakness in internal control involved revenue recognition, only one action in 2020 involved revenue recognition.

PCAOB bodog casino involving announcements of restatements and/or internal control weakness by year finalized 2015-2020

The Number of Unique PCAOB bodog casino Substantially Decreased
  • At times, PCAOB bodog casino involve other relevant entities and/or individuals. The PCAOB identifies related bodog casino that are settled or otherwise finalized as a separate action. In certain instances, related bodog casino were settled on different dates and/or included different allegations.
  • Of the 13 PCAOB bodog casino in 2020, three (23%) were identified by the PCAOB as being related to other action(s), consistent with prior years.
  • In 2020, there were 10 unique PCAOB bodog casino, a 60% decrease from the 2015–2019 average (25), and a 71% decrease from the peak in 2017 (35).

Unique PCAOB bodog casino by year finalized 2015-2020

PCAOB bodog casino Involved Substantially Fewer Respondents in 2020
  • The total number of respondents in 2020 PCAOB bodog casino decreased 33% from 2019 and was about half of the 2015–2019 average.
  • In 2020, almost two-thirds of the bodog casino involved a firm and at least one individual auditor, up from the 2015–2019 average of 46%.

Respondents in PCAOB bodog casino by Year Finalized 2015–2020

Total Monetary Settlements in 2020 PCAOB bodog casino Were Approximately .5 Million
  • In addition to bars, suspensions, and other nonmonetary sanctions, the bodog casino imposed monetary settlements against 77% of respondents in 2020, up from 60% in 2019. The increase was driven by the imposition of monetary settlements against 76% of individuals, up from 48% in 2019.
  • The bodog casino imposed monetary settlements against 78% of firms in 2020, down from 85% in 2019.
  • Total monetary settlements against individuals were 5,000, which was ,000 higher than in 2019. The median settlement increased from ,000 in 2019 to ,000 in 2020.
  • Total monetary settlements against firms were ,285,000 in 2020, 5,000 lower than in 2019. The median settlement in 2020 remained unchanged from 2019, but the average settlement in 2020 against firms increased 14% from the 2019 average.

Monetary Settlements in Settled PCAOB bodog casino 2018–2020 ($ amounts in thousands)


1 As required by the Sarbanes-Oxley Act, the PCAOB keeps its investigations and disciplinary proceedings confidential and nonpublic until the matter is settled or otherwise finalized. See “bodog casino,” PCAOB website, https://pcaobus.org/bodog casino/Pages/default.aspx.

2 In a speech on October 8, 2020, then bodog casino Chair Jay Clayton stated, “I am pleased to report that while the pandemic significantly impacted how we do our work, it did not negatively impact the work itself.” Jay Clayton, “An Update on FY 2020 Results,” Remarks at bodog casino Speaks, Washington D.C., October 8, 2020, https://www.bodog casinogov/news/speech/clayton-bodog casino-speaks-2020-10-08. See also Stephanie Avakian, “Protecting Everyday Investors and Preserving Market Integrity: The SEC’s Division of bodog casino,” Remarks at the Institute for Law and Economics, University of Pennsylvania, September 17, 2020, https://www.bodog casinogov/news/speech/avakian-protecting-everyday-investors-091720 (“Since mid-March, the entire Division [of bodog casino] has been working from home. . . . [S]ince mid-March, the Commission has filed more than 325 new bodog casino actions.”).

3 In Liu v. bodog casino, the Supreme Court held that disgorgement awards sought by the SEC in federal courts are an equitable remedy permitted by the federal securities laws if capped to the wrongdoer’s net profits and awarded for the benefit of wronged investors. See Stephanie Avakian, “Protecting Everyday Investors and Preserving Market Integrity: The SEC’s Division of bodog casino,” Remarks at the Institute for Law and Economics, University of Pennsylvania, September 17, 2020, https://www.bodog casinogov/news/speech/avakian-protecting-everyday-investors-091720. See also Liu et al. v. Securities and Exchange Commission, No. 18-1501, 591 U.S. ___ (2020), https://www.supremecourt.gov/opinions/19pdf/18-1501_8n5a.pdf.

4 In a speech on September 17, 2020, then SEC Division of bodog casino Director Stephanie Avakian stated, “We have also focused on rewarding and messaging the benefits of cooperation. We recognize the value in providing greater transparency into how the Commission considers and weighs cooperation credit – meaningful cooperation can substantially accelerate an investigation, which is in everyone’s interest. We have tried to message more clearly the benefits of cooperation and in a number of instances the Commission has provided that information in its orders.” Stephanie Avakian, “Protecting Everyday Investors and Preserving Market Integrity: The SEC’s Division of bodog casino,” Remarks at the Institute for Law and Economics, University of Pennsylvania, September 17, 2020,  https://www.bodog casinogov/news/speech/avakian-protecting-everyday-investors-091720.

5 See “bodog casino,” PCAOB website, https://pcaobus.org/bodog casino/Pages/default.aspx.


The views expressed herein are solely those bodog casino authors, who are responsible for the content, and do not necessarily reflect the views of Cornerstone Research.

Authors

  • Los Angeles

Elaine M. Harwood

Senior Vice President

  • Washington

Simona Mola

Principal

Research Sample and Data Sources

This research examines trends in accounting and auditing bodog casino actions that were publicly disclosed by the U.S. Securities and Exchange Commission (SEC) and the Public Company Accounting Oversight Board (PCAOB) between 2015 and 2020.

Accounting and auditing bodog casino actions include (1) SEC Accounting and Auditing bodog casino Releases (AAERs) listed in the SEC Division of bodog casino Annual Reports and available on the SEC’s website at https://www.bodog casinogov (“SEC bodog casino”), and (2) PCAOB settled and adjudicated disciplinary orders available on the PCAOB’s website at https://pcaobus.org (“PCAOB bodog casino”). SEC bodog casino exclude follow-on administrative proceedings. SEC and PCAOB auditing bodog casino exclude bodog casino unrelated to the performance of an audit (e.g., failure to register with the PCAOB or to timely disclose certain reportable events to the PCAOB).

Respondents in PCAOB bodog casino actions and SEC administrative proceedings and defendants in SEC civil proceedings are referred to as “respondents.” Respondents include (1) SEC registrants and audit firms (“firms”), and (2) individuals employed by or associated with SEC registrants and audit firms (“individuals” or “related individuals”).

bodog casino that involve one firm respondent are considered “non-U.S.” if the firm is headquartered outside the U.S. bodog casino that involve multiple firm respondents are considered “non-U.S.” if (1) all of the firm respondents are headquartered outside the U.S., or (2) one or more of the firm respondents are headquartered outside the U.S. and the alleged violations occurred outside the U.S. bodog casino that only involve individual respondents are considered “non-U.S.” if (1) the individuals are licensed or reside outside the U.S., and (2) the alleged violations occurred outside the U.S. All data are reported on a calendar year basis.

bodog casino involving restatements are bodog casino that refer to an announcement that the company will restate, may restate, or has unreliable financial statements. bodog casino involving material weaknesses in internal control are bodog casino that refer to an announcement that the company has a material weakness in internal control.

Monetary settlements include penalties, disgorgement, and prejudgment interest. Settlements include all bodog casino settled during the year, regardless of when the action was initiated.