backOn December 4, 2025, the PCAOB announced a settled disciplinary order against TPS Thayer LLC (the “Firm”), censuring the Firm, imposing a $100,000 civil penalty, and requiring contingent remedial undertakings. The matter arose from five audits of two issuers with principal places of business in China, in which an unregistered China-based firm performed a substantial role.
According to the Board, the Firm failed to adequately plan the audits and exercise due professional care; failed to reasonably supervise the unregistered firm, which exceeded 20% of total audit hours in each of the five audits and, therefore, played a “substantial role” in violation of Section 102(a) of the Sarbanes-Oxley Act and PCAOB Rule 2100; and failed to disclose the unregistered firm’s participation on Form APs and to the issuers’ audit committees in violation of PCAOB Rule 3211 and AS 1301. The Board also found quality control system deficiencies because the Firm’s policies did not address substantial role participation by other accounting firms, which contributed to the disclosure failures.
The settled order is available here.