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information that is learned through the inspection process can be used as a basis for modifying
and enhancing auditing standards.
b. These sections improve auditor independence by separating consulting and auditing by
the same audit firm. The partner rotation requirement ensures that a “fresh set of eyes” will be
responsible for oversight on the engagement.
c. The “cooling off” period helps to avoid conflicts of interest between top members of the
engagement team and the client. By requiring a cooling off period, an auditor will not be unduly
influenced (or appear to be unduly influenced) by the possibility of high-level employment with
the client.
e. The certification requirements help address the risk of fraud by forcing the CEO and CFO
to take internal controls and high quality financial reporting seriously. By forcing them to sign,
they will likely require individuals below them to provide assurance that those departments or
organizational units are each committed to internal controls and high quality financial reporting
as well. Of course, a signature is just a signature! So, the likelihood that a CFO who is
committing fraud will certify falsely is probably 100%. Thus, this mechanism is not without
practical flaws.
f. It addresses off-balance sheet transactions and special purpose entities, which were the
main mechanisms used to conduct the Enron fraud.
h. One member of the audit committee needs to be a financial expert to ensure that there is
the knowledge necessary on the audit committee to critically evaluate management’s financial
reporting and internal control choices. Without that knowledge, the committee may be unduly
influenced by management’s preferences.