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Case 5-4 Busy Season Planning
Romello Accounting LLP is a small CPA firm consisting of three partners and seven other
professional staff. The firm offers full attestation and assurance services. Most of the work is for
small and medium-sized nonpublic companies. The firm is registered with the PCAOB and does
audits of about 30 penny stock or pink sheet companies and broker-dealers each year.
Tony Romello, the managing partner of the firm, has been the review partner on all audits for the
last several years. Unfortunately, Tony encountered major health concerns in the last month and
will not be available for the upcoming busy season. Michelle Thompson and Max King, the two
remaining partners, are discussing staffing during the busy season.
Questions
Consider the staffing of audits in responding to the following questions.
1. Identify the stakeholders of audits and their interests. Is there a difference between
stakeholders and interests of public versus nonpublic companies?
The stakeholders include the following.
Michelle and Max, the two partners debating how to best select a review partner
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Tony, who is the managing partner of the firm but has major health problems and
can’t serve as a review partner
The firm Romello Accounting LLP
The PCAOB because of its oversight role and inspections
applies to auditors of both public and nonpublic companies.
2. What are a firm’s considerations in having review partners? Does it really matter
from a professional judgment perspective whether review partners rotate off after a
prescribed number of years? Use the KPMG Professional Judgment Framework to
support your response.
Although not addressed directly in this chapter, PCAOB Auditing Standard No. 7, Engagement
Quality Review, provides that an engagement quality review and concurring approval of
issuance of an audit report are required for the following engagements conducted pursuant to the
standards of the PCAOB: (a) an audit engagement; (b) a review of interim financial information;
and (c) an attestation engagement. The objective of the engagement quality reviewer is to
perform an evaluation of the significant judgments made by the engagement team and the related
conclusions reached in forming the overall conclusion on the engagement and in preparing the
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important for audit professionals: the availability tendency, the confirmation tendency, the
overconfidence tendency, and the anchoring tendency.
The availability tendency may lead to judgments based on the accessibility of information rather
than a deliberative analysis of how the facts of the current situation differs from prior ones. Also,
an auditor may rely on past procedures in the current audit even though that approach may not be
relevant to the current situation. This could lead to a major problem that might be alleviated
through rotation.
Extended Discussion
Mandatory auditor (firm) rotation
The danger of audit firms conducting audits of clients over an extended period of time is the
regular audits should not become a sort of long-term annuity for the accounting firm paid for by
the company being audited, rather than being responsive to the investing public. A fresh
perspective supports an independent mindset and strengthens objectivity in conducting the audit.
process in conjunction with the external auditors and should monitor the auditors’ activities.
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Perhaps the onus should be placed on an independent audit committee to ensure that auditors
with a long tenure with the company do not compromise their judgments or cut corners in the
audit.
The PCAOB has proposed mandatory rotation of audit firms by setting limits on the number of
consecutive years that a registered public accounting firm could serve as the auditor of a public
Will rotating accounting firms enhance audit quality?
Perceived advantages
The perceived advantages of mandatory rotation of audit firms largely center on increased audit
quality. Proponents of the PCAOB proposal posit that term limits would help to eliminate some
of the closeness that may exist between audit firms and clients, thereby promoting increased
independence, skepticism and objectivity. There are often situations where auditors may want to
maintain the relationship as opposed to performing the best audit. When an auditor knows that
their relationship is nearing its end in the future, the auditor’s main concern should be to conduct
the audit effectively and efficiently rather than getting hired next year.
Perceived disadvantages
As with any proposal, there are perceived disadvantages to mandatory rotation of audit firms. It
is apparent that term limits could result in the loss of major clients and sources of revenue for
audit firms. Also, the specialized nature of certain industries often necessitates that companies
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firm term limits may preclude companies from selecting audit firms; thus, the company’s audit
committee may have to relinquish its role in the vetting and selection of the audit firm, thereby
diluting the committee’s impact.
In order to perform a quality audit, auditors have to understand their clients’ businesses. This
process requires time and resources on the part of both the audit firm and the client. Further, the
time it takes to understand a new client may in fact increase the risk of audit failure in the first
few years of an audit. There are a lot of costs, and as is the case with any audit, there is a
Recommendations from the Institute of Internal Auditors
Lawrence Harrington, chairman of the North American board of the Institute of Internal
Auditors (IIA), delivered the following recommendations regarding mandatory audit firm
rotation at a PCAOB hearing on March 22, 2012.
2
I am strongly opposed to mandatory rotation of external auditing firms based on a fixed time
schedule. Much of the potential benefit of auditor rotation has already been achieved through
• Introducing a mandatory change of auditors in limited circumstances such as financial
statement fraud.
• Requiring increased disclosure about the audit committee’s role in overseeing the quality of the
audit, including its periodic evaluation of auditor independence.
• Implementing a system whereby audit committees could request the PCAOB to perform an
enhanced inspection of the audit of their company, with reporting of results to both the company
and its auditors.
I believe the board should continue to focus on ways to enhance auditor independence,
objectivity and professional skepticism. To this end, rather than requiring mandatory firm
rotation, the PCAOB should consider each of the alternatives presented above, with the goal of
increasing the overall efficiency and effectiveness of auditing without incurring the significant
risks inherent in mandatory auditor rotation.
3. Assume Max convinces Michelle to let him serve as the review partner for all audits
and Michelle will serve as the engagement partner on all audits. Do you see any
problems with this approach from an ethical perspective?
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