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PCAOB ramps up enforcement as it faces possible shutdown

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The Public Company Accounting Oversight Board increased its enforcement activity in 2024 to its highest level since 2017, according to a new report, even as the PCAOB faces the prospect of perhaps being absorbed in the Securities and Exchange Commission.

The report, released Wednesday by Cornerstone Research, found that monetary penalties levied by the PCAOB reached their highest for the third consecutive year. The report also compares PCAOB enforcement activity under President Biden to President Trump’s first term.

The report found the PCAOB publicly disclosed 51 total enforcement actions, including 40 actions involving the performance of an audit. Most of these actions came in the first half of the year, with only 10 auditing actions finalized after the Supreme Court ruled against the use of administrative law judges in SEC v. Jarkesy. At $35.7 million, the number of total monetary penalties in 2024 marked a 78% increase over 2023 and represented nearly 40% of all monetary penalties imposed since the PCAOB’s inception.

“The PCAOB continued aggressive enforcement in 2024, finalizing 30 auditing actions in the first half of 2024, more than triple the number of actions finalized in the first half of 2023,” said Jean-Philippe Poissant, one of the report’s co-authors and co-head of Cornerstone Research’s accounting practice, in a statement. “In one in five auditing actions, the PCAOB alleged violations of not only auditing standards, but quality control standards and ethics and independence, as well.”

The report compares PCAOB enforcement under the Biden administration, and found that under the Biden administration, the PCAOB finalized 160 total actions, including 124 auditing actions, compared to 126 and 101, respectively, under the Trump administration. The total value of the monetary penalties imposed were nearly seven times higher during the Biden administration, reaching approximately $68 million, compared to just over $10 million during the first Trump administration.

“The type of respondents in enforcement actions shifted from a majority of individual respondents during the Trump administration to a near even split between individual and firm respondents during the Biden administration,” said Russell Molter, a principal at Cornerstone Research and report coauthor, in a statement. “Additionally, the percentage of respondents fined in Auditing Actions climbed from a little over half (59%) to nearly all respondents (94%).”

With 2024 marking the 20th year since the PCAOB finalized its first enforcement action, the report also analyzed the agency’s enforcement results in the past two decades. In these 20 years, the PCAOB finalized 487 total actions involving 675 respondents, the majority of which (344) were individuals. The PCAOB has imposed $94 million in monetary penalties since its inception.

Changes at the PCAOB and SEC

The report’s release coincides with new concerns over the future of the PCAOB under the Trump administration, which has been laying off thousands of federal employees as part of a cost-cutting initiative, while moving to all but close down agencies such as the Consumer Financial Protection Bureau and the U.S. Agency for International Development. The aggressive work of the PCAOB has occurred under PCAOB chair Erica Williams who was brought in by former SEC chair Gary Gensler with a mandate to get tougher on auditing firms and ramp up inspections, enforcement and standard-setting. The Heritage Foundation’s Project 2025 planning document that was circulated prior to Trump’s election called for the PCAOB to be abolished, along with the Financial Industry Regulatory Authority, and said their regulatory functions should be absorbed into the SEC.

Trump has nominated Paul Atkins, a former SEC commissioner who was previously critical of the PCAOB, as the next chair of the SEC. That could prompt another wave of turnovers at the board, as occurred during the previous Trump administration and the Biden administration.

“As it relates to the PCAOB and the SEC, I think there’s been a lot of projection, a lot of hypotheses or predictions that the PCAOB would be folded into the SEC based upon prior views of the administration or Chairman Atkins,” said Andrew Gragnani, president of CBIZ CPAs P.C. “That leads to a lot of questions regarding the nature and timing of inspections, the nature and timing of funding, etc. It does not change the need to continue to perform high-quality audits. We’re not planning that there will be wholesale changes to the inspection process. I don’t think that’s a healthy way to look at how this will all play out, but there are changes that people have projected that would impact firms. I think the primary one that people are focused on with the administration is the view that there’ll be less enforcement activity, so that obviously would be one that would be most significant to the firms, given that the PCAOB, under Chairman Williams, has been very active in their enforcement against firms for inspections. That might be the most meaningful change if there was to be this folding of the PCAOB into the SEC. That’s the one major expectation from the administration that has been anticipated.”

Dan Goelzer, one of the original members of the PCAOB and later an acting chair, recently told Accounting Today that a change in the composition of the board is likely.

“I suppose it’s probably pretty likely that there will be maybe a complete change in the membership of the board,” said Dan Goelzer, one of the original members of the PCAOB and later an acting chair. “That happened both of the last times around when there was a change in administration. I don’t really say that with any pleasure. I’d rather see a less political PCAOB. But as a practical matter, I certainly think the new SEC would look to change the chair of the PCAOB — I suppose that’s quite likely at least — and some of the other board members as well.”

There may be a restructuring of the PCAOB as well, along with its possible absorption into the SEC. “The other big picture issue is whether broad efforts to restructure or streamline the government are going to include the idea of folding the PCAOB into the SEC,” said Goelzer. “That came up during the prior Trump administration and was actually proposed in one of Trump’s budgets, and it’s in the Heritage Foundation report. I suspect that will come up as a discussion item, at least. Whether it would actually make it through Congress is far from clear.”

The SEC has overhauled the membership of the PCAOB under Gensler, and during the Trump administration under former SEC chair Jay Clayton, but there were some differences. 

“I do think there’s a distinguishing factor with Jay Clayton in that most, if not all, of the PCAOB board members at that time were serving on expired terms, which was different from four years later, when Gary Gensler was the chair,” said Center for Audit Quality CEO Julie Bell Lindsay. 

She believes effective oversight of the audit profession requires impartiality without political considerations. “The pendulum swinging back and forth every four years is not good,” said Bell Lindsay. “It’s not conducive for long-term audit quality. It’s not conducive to market efficiency and to stability of the capital markets. We would like to avoid the pendulum swinging every four years.”

She pointed out that both the SEC and the PCAOB have enforcement authority over auditors.

“With respect to enforcement over the public company audit profession, there are two cops on the beat,” said Bell Lindsay. “Both the PCAOB and the SEC have enforcement authority when it comes to public company auditors. Where there are bad actors, bad actors need to be held to account. The pendulum has swung pretty far in one direction, and there have been some concerns about the impact of the current enforcement thinking when it comes to retention of talent in the audit profession. This is not a profession that is necessarily bursting at the seams with new talent coming in, so the impact on talent and on public company audit firms wanting to stay in the business of auditing public companies. I think it’s really important to remember that at least 75% of the mid to small cap companies in the U.S. are serviced by mid to small size public company audit firms. A huge swath of the marketplace is serviced by small to mid sized public company auditors, and the impact that standard-setting, enforcement, etc can have on those firms can have unintended consequences.”

Goelzer is seeing similar concerns expressed at small auditing firms. “I’ve certainly heard people say that smaller firms are reconsidering whether they want to be engaged in public company auditing,” he said. “If you only have a handful of public company clients, you look at these penalties and the cost of complying with new auditing standards and regulations, firms may well conclude that they’ll simply leave this space and concentrate on private company auditing or other kinds of services for clients that has a spillover effect than on smaller public companies, which have less auditor choice, and probably increased audit fees as a result.”

The PCAOB board composition is likely to change at the very least. “If you think back to the previous administration, there was a complete overhaul of the board last time around, and we expect that there will be a similar reaction to the regime change,” said Jackson Johnson, president of Johnson Global Advisory, a Washington, D.C.-based firm that helps auditing firms navigate the PCAOB inspection process. “I do expect that the majority of the board will be replaced.”

He expects to see the SEC and the PCAOB taking a less aggressive stance and levying fewer penalties. “The current board’s priorities were to use enforcement as a regulatory tool, more standards and more enforcement,” said Johnson. “The next board will be quite different. The next board will be a more collaborative mindset with firms, more information gathering with stakeholders, more economic analysis to inform standard setting, more robust economic analysis to inform standard setting.”

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GT soups up compliance capacities with AI-based platform

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Compliance professionals at top 10 firm Grant Thornton will now be making use of the newly-enhanced CompliAI platform, which has gone from a largely spreadsheet-driven classic automation solution to one infused with generative AI from end to end to streamline and enhance service delivery. 

The platform uses advanced AI capabilities, including GenAI Assistants and a GPT Model Series to automate key tasks such as risk and control rationalization, question and procedure generation, and document request list creation. For example, it will suggest questions for the professional to ask, and based on the answers, generate additional followup questions and tasks. The software also features a suite of tools, including dashboards, task management, in-app commenting, notifications, a methodology document library, and a centralized file repository. This is so professionals can conduct tasks in minutes that would have traditionally taken days or weeks. 

Mike Kempe, chief information officer of Grant Thornton Advisors, noted that beyond efficiencies, another major intention with this solution was to create a more consistent experience for their clients. Different professionals approach things in different ways, both in and out of the accounting world, and so the client experience can vary widely depending on who is working on an engagement at a given time. It is hoped that this new platform can smooth out some of that variation so clients can get a better idea of what to expect. 

“We’re providing a better service to our client and a much more consistent one as well because we’re no longer relying on the quality of individuals, we’re relying on AI… In the past, the issue was that if I was providing a service I would do it one way, and [if] John was providing the service, he would do it a different way, so clients would get inconsistent quality. With this, we increase the quality, and it’s going to be much more consistent,” he said. 

Paradoxically, though, he believes this will actually serve to create a more, not less, personalized experience for clients. By using AI to get through the routine processes that the accountant would ordinarily be doing themselves, they have more time and energy for close collaboration with the specific client and so can take on a more strategic role in compliance engagements. 

“Our professionals right now [are focused] on how to use AI and on building that relationship with the client and making this a much more personalized service than we have had in the past,” he said. 

The newly-enhanced CompliAI platform is just one more step in GT’s wider AI ambitions. Kempe said they plan to replicate this approach across many more service sectors. The firm has a roadmap for at least five more AI-based solutions released over the next year and a half as part of its vision to incorporate the technology throughout its numerous practice areas. When pressed on the particulars he declined to be too specific, but said people can expect many different solutions. 

“There’s a lot of productivity solutions that we’re building at the moment, and we’re working with our partners and some startups as well [to roll it our internally.] There’s a couple more AI solutions in the audit space as well as in the tax space that we’re currently working on… But suffice to say, we’re investing heavily. We’re on a very significant roadmap to put AI into everything we do. That’s our mission,” he said. 

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Accounting firms should start auditing AI algorithms

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Wall Street has learned the hard way that black-box models can wreck balance sheets. Enron’s off-ledger special-purpose entities fooled analysts because auditors lacked the tools, or the will, to probe opaque structures. 

Two decades later, AI presents an even thornier transparency challenge, yet the accounting profession already owns the mindset to fix it. We can turn the audit playbook into an AI assurance framework that policymakers have been groping for.

A year ago, the Center for Audit Quality surveyed partners across industries and found that one in three companies has already embedded generative AI in core financial processes. That wave is cresting before governance rules are in place. The CAQ warned that model drift, undetected bias and hallucinated explanations could all distort financial statements if engagement teams rely on AI without documented controls.

The National Institute of Standards and Technology released the AI Risk Management Framework 1.0 in January 2023 after input from more than 240 organizations. A generative-AI profile, added in July 2024, provides detailed guidance for managing risks like prompt logging, hallucination and bias in generative models. Big adopters, including Microsoft and Workday, have already mapped their internal controls to the NIST RMF.

Regulators are starting to echo that warning. The Public Company Accounting Oversight Board issued a spotlight last July that could not be clearer. Humans remain responsible for any work product produced with AI assistance, and auditors must document how they evaluated the tool. It is accounting’s Sarbanes-Oxley moment for neural nets. If we seize it, we can shape a pragmatic oversight regime.

What would that look like? Start with the three legs every auditor knows: evidence, materiality and independence. Evidence means logging every prompt and output so reviewers can replicate the conclusion. Materiality means setting quantifiable tolerances for algorithmic error, not hand-waving about “low risk.” Independence means assigning a separate team, ideally with data scientists who hold no stake in the model’s success, to challenge assumptions. None of these ideas requires a new federal agency. They require extending time-tested audit standards to predictive code.

Europe has fired the opening shot. The EU AI Act classifies AI used in finance and education as “high risk” and mandates conformity assessments before deployment. U.S. firms operating in both markets will soon discover that the cost of exporting software can dwarf the cost of exporting widgets if documentation is sloppy. American regulators need not mimic the EU AI Act clause for clause, but they should embrace the Act’s insight: riskier models deserve stricter audits.

The National Telecommunications and Information Administration agrees. Its March 2024 report sketches an AI accountability ecosystem built on third-party audits, incident registries, and benchmark datasets. That is music to accountants’ ears; it sounds like GAAP for algorithms. Auditors have spent a century refining peer review, work-paper retention, and inspection cycles; they can transplant those muscles to model assurance with minimal retooling.

Skeptics worry about talent shortages, yet firms once trained auditors in statistical sampling when that was new. Tomorrow’s audit associate will need R or Python alongside pivots, but the pedagogy remains: test controls, document exceptions and issue an opinion. The pipeline problem is solvable if higher education integrates AI ethics and assurance modules into accounting curricula now.

A second objection is competitive secrecy. Companies say revealing model internals will hand over trade secrets to rivals. Audit protocols offer a compromise: confidentiality agreements for reviewers plus public summaries of findings, akin to key audit matters. Investors care less about the recipe than about the assurance that the chef followed food-safety rules.

History offers a precedent. When Congress created the Securities and Exchange Commission in 1934, financial statements suddenly had to meet public standards. Far from stifling growth, transparency fueled the longest bull run in history by lowering information risk. AI assurance can do the same. Markets crave clarity more than ever as algorithms move from back-office helpers to decision makers that allocate credit, price insurance and flag Suspicious Activity Reports.

The next 12 months are decisive. The PCAOB is weighing whether to update its audit standards explicitly for AI. Instead of waiting, firms should pilot voluntary algorithm audits and publish the results. The first mover will earn reputational capital that no marketing budget can buy, and the blueprint will help regulators draft proportionate rules.

Trust has always been accounting’s export. In the AI era, the ledger expands from debits and credits to tokens and weights. The discipline that once tamed creative bookkeeping can now tame creative code, and that, more than any flashy demo, is what will keep capital flowing. Audit survived spreadsheets; it will thrive on silicon.

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Trump pushes SALT Republicans to abandon further increase

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President Donald Trump on Tuesday pushed back on demands from Republicans who have threatened to sink his giant tax bill if the legislation does not significantly boost the state and local tax deduction, said Representative Mark Amodei of Nevada. 

In a private meeting with House Republicans, Trump singled out the lawmakers from New York, New Jersey and California who have rejected the $30,000 deduction limit — three times the current cap — contained in the legislation moving through the House.

“He wants to leave it where it is, that’s basically what he said,” Representative Bruce Westerman of Arkansas said of the SALT provision in the bill after the meeting. 

The confrontation came moments after Trump told reporters the SALT deduction benefits Democratic states and politicians, signaling that the tax break, which predominantly benefits high-tax states like New York, New Jersey and California, isn’t a central concern of Republicans.

“It’s not a question of holdouts. We have a tremendously unified party,” Trump said Tuesday before meeting with lawmakers. “There’s some people that want a couple of things that maybe I don’t like or that they’re not going to get.”

Still, Trump has repeatedly pledged bigger SALT deductions, which were limited in his first-term tax cut bill. A faction of Republicans from high-tax states have threatened to sink Trump’s agenda over SALT. Trump, however, shrugged off those concerns. 

“There are one or two points some people feel strongly about, but maybe not so strongly,” Trump said ahead of the meeting. 

House Speaker Mike Johnson met with those SALT holdouts late Monday, but left without an agreement.

Representative Nick LaLota, a New York Republican, said House leaders offered a SALT proposal that would temporarily raise the cap higher than the $30,000 in the draft bill, before reverting back to the lower level. 

“Any proposal that has the cap falling off a cliff is unacceptable to me,” LaLota told reporters Tuesday morning. “Now is the time to get it right.”

Another New York Republican, Mike Lawler, told reporters there is no SALT deal and a vote on the bill — planned for as soon as Wednesday — will fail without one.

Johnson was more positive about the chances for a deal. He still plans for the House to vote on the package by the end of the week. 

“We’re going to get an agreement on everything necessary to get this over the line,” he said Tuesday.

The bill approved last week by the House tax committee sets a $30,000 cap for individuals and couples. That draft called for phasing down the deduction for those earning $400,000 or more, a plan quickly rejected by several lawmakers who called it insultingly low. The current writeoff is capped at $10,000.

Stephen Miran, who chairs the White House Council of Economic Advisors, said he was confident Trump would be able to quickly reach a deal on SALT with House Republicans.

“The president will deliver SALT relief to American households. I don’t know exactly what the number will shake out,” Miran told Bloomberg Television on Tuesday. “The president is one of the best negotiators in history and he’s shown over a career spanning decades that he can forge hundreds of deals and I think he’ll forge another one right in front of us now.”

The holdout lawmakers — who also include New York’s Andrew Garbarino and Elise Stefanik, New Jersey’s Tom Kean and Young Kim of California — have threatened to reject any tax package that does not raise the SALT cap sufficiently.

Garbarino said Johnson made the group several offers and that they’re awaiting more analysis Tuesday morning. 

“I’m just happy we’re having the discussion and they’re working with us,” Garbarino said.

Republicans are also squabbling over spending reductions in the bill, including weighing cuts to Medicaid health coverage and nutritional programs for low-income households.

They are trying to keep revenue losses from their tax-cut package down to a self-imposed limit of $4.5 trillion over 10 years. The current package has a $3.8- trillion revenue loss.

— With assistance from Jamie Tarabay, Jonathan Ferro, Skylar Woodhouse, Catherine Lucey, Jack Fitzpatrick, Steven T. Dennis and Ari Natter.

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