backOn November 19, 2024, without admitting or denying findings, five firms settled with the PCAOB for failing to make required disclosures. The firms include Bush & Associates CPA LLC (“Bush”), Barton CPA PLLC (“Barton”), Crowe Hussain Chaudhury & Co. (“Crowe”), B S R & Co. LLP (“KPMG India”), and RSM Brasil Auditores Independentes Sociedade Simples (“RSM Brazil”).
Pursuant to PCAOB Rule 3211, Auditor Reporting of Certain Audit Participants, registered public accounting firms must file a Form AP for each audit report issued by the firm for an issuer no later than the 35th day after the audit report is included in a document filed with the SEC. According to the PCAOB, Barton failed to file multiple required Form APs within the specified time frame, and Bush and Crowe failed entirely to file multiple required Form APs until notified of that delinquency by PCAOB staff. Additionally, PCAOB Rule 2203, Special Reports, requires that registered public accounting firms file a Form 3 disclosing certain reportable events listed in that form within 30 days of the occurrence of those events. These events include the initiation of certain criminal, regulatory, administrative, or disciplinary proceedings against a firm or its personnel. According to the PCAOB, KPMG India and RSM Brazil both failed to timely report the initiation of multiple disciplinary proceedings brought against those firms (and, in the case of KPMG India, its personnel) by local regulators.
The PCAOB censured all five firms and imposed civil money penalties of $50,000 on Bush and $25,000 each on Barton, Crowe, KPMG India, and RSM Brazil. The orders also require each of the firms to undertake remedial measures to improve their policies and procedures concerning compliance with PCAOB reporting.
The PCAOB press release and settled orders are available here.