Wednesday, January 10, 2007

Open Letter to Public Company Accounting Oversight Board

Dear Public Company Accounting Oversight Board:

According to Section 104 of the Sarbanes-Oxley Act you are required to “conduct a continuing program of inspections of registered public accounting firms.”

I am trying to determine how many such inspections you conduct with your limited resources by each individual accounting firm and the scope of each inspection. In addition I would like you to provide the public with the percentage of how many such inspections result in audit deficiency citations by each firm. If you can further classify such audit deficiency citations by degree of seriousness as it relates to the total number of inspections conducted that too would be appreciated.
If you have any questions, please call me (my phone number is listed on my web site

The public needs to know the relative quality of the audits of public companies by the accounting profession. After reviewing your web site I believe that inadequate data exists to make such a determination.

The inspection reports are too vague to get any meaningful quantifiable information as to the overall quality of audits conducted by individual firms. For example there is no direct information on any of the inspection reports that tells of the total amount of audit inspections conducted. It only gives the total amount of field offices visited.

I sent you an e-mail requesting certain information below:
  • Does the PCAOB release statistical information as to how many such inspections are conducted? (By each Auditor and overall)
  • Does the PCAOB release statistical information as to the scope of the inspections done? (By each Auditor and overall)
  • Does the PCAOB release statistical information as to the percentage of inspections that result in deficiencies? (By each Auditor and overall)
  • Does the PCAOB release statistical information of the possible or potential economic impact of deficiencies as a percentage of each audit and total audits inspected? (By each Auditor and overall) (By each Auditor and overall)
  • Would the PCAOB release any of the above information if available? (By each Auditor and overall)
  • Would the PCAOB release any statistical analysis as to the overall quality of the audits it inspects? (By each Auditor and overall)

I received the following reply from you:

The PCAOB has determined what information is to be made public via the public portions of the inspection reports, which can be found on the PCAOB’s website: and the annual report it issues.
Thank you

After receiving the e-mail I found out that the PCAOB in its Annual Report does release the total number of inspections but does not break down the information by individual firm. It is impossible to derive that information by individual firm since the PCAOB does not provide individual audit firm inspection amounts. The PCAOB should have such information readily accessible.

As an entity that is supposed to promote transparency in financial information I find such an answer both unsatisfactory and appalling. I do not believe you need to be lectured by an ex-felon whose very actions helped contribute to the creation of the Sarbanes-Oxley statute and your agency.

However, you should know that unlike most CPAs (many of whom serve in your entity) who passed the CPA exam being members of the (300 club with the curb) my average was 91.25% so I know a little bit about accounting. From my experience as a criminal I know a lot about white collar crime and your reason for being.

If I sound a little upset at you I am. Please do not play the side step with a felon like me who knows the game all to well. Be forthright and present your information front and center. If it is hidden some where on your website show it up front.

Now if it’s the law that is preventing such disclosure write a letter to Congress and change it. It should take about a week to get your people together to get the signatures. You have had years to do it. If the data is available it takes one of your people about a couple of days with an Excel spreadsheet to put it on your website front and center so every can read it and analyze it without going around circles.

Others are questioning your constitutionality. I have been a staunch ally. Maybe we should start from square one. If that actually happens, God help us all.


Sam E. Antar (former Crazy Eddie CFO & ex-felon)

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