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The most recent case brought in this area by the agency is a good example of the importance of these cases – the engagement partner ordered that an unqualified audit opinion be issued despite the fact that the field work had not been completed and critical procedures had not been conducted. Essentially the audit work was “backdated.” In the Matter of Richard J. In the first week of January the SEC staff issued a subpoena to BDO, requesting copies of the firm’s work papers and audit files related to Am Trust. Bertuglia focused on substantially completing the work on all major financial statement audit areas prior to the time Am Trust issued its earnings release on February 13, 2014. The proceeding center on the audit by BDO USA, LLP of the financial statements of Am Trust Financial Services, Inc., an underwriter of casualty insurance, to be included in the 2013 Form 10-K, filed in March 2014 with the Commission. BDO was engaged by Am Trust to conduct an integrated audit of the firm’s 2013 consolidated annual financial statements and ICFR in accord with PCAOB standards (“Consolidated Audit”).This brings the number the number of companies sued in securities fraud class action lawsuits based on options timing allegations to eight.Background on the other seven companies previously named can be found on prior A sense of the magnitude of the problems that options backdating can cause can be found in Mercury Interactive’s July 3, 2006 release of its restated financials.For the incomplete, predated work papers, including those that were placeholders, the team generally overwrote the documents thereby replacing the prior documentation with new papers reflecting the work done and evidence obtained.

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· Substantive tests, material accounts: There was incomplete testing for material accounts identified in the audit plan concerning premium revenue, premium receivables, and share-based compensation.

To resolve the proceedings each Respondent consented to the entry of an order based on Rule 102(e)(1)(ii) denying them the privilege of appearing or practicing before the Commission as an accountant with the right to apply for reinstatement after: as to Mr.