Heightened PCAOB and SEC Enforcement Against Auditors Continues in H1 2024, According to Brattle Report
According to a new report from The Brattle Group, total Public Company Accounting Oversight Board (PCAOB) and US Securities and Exchange Commission (SEC) enforcement activity against auditors in the first half of 2024 is significantly outpacing the number of enforcement actions brought by the regulators in recent years. In fact, the PCAOB has already brought more actions in the first six months of the year than it did in each full year under its prior administration (2018–2021).
The report, Enforcement Activity Involving Auditors – 2024 Mid-Year Update, highlights PCAOB and SEC enforcement activity thus far in 2024. It follows the January 2024 release of 2023 Enforcement Activity Involving Auditors, which analyzed overall PCAOB and SEC enforcement activity during 2018–2023, including a comparison of activity during the regulators’ current and prior administrations. The mid-year update finds that the heightened trend of enforcement established in the past two years is continuing in 2024 for the PCAOB, though SEC enforcement activity has been off to a slower start.
“PCAOB enforcement in 2024 is off to its fastest start in the agency’s history, bringing 34 actions against 45 respondents and imposing a record $35 million in penalties by the end of June,” said Brattle Principal Alison Forman, who authored the report with Associate Adam Karageorge. “And the SEC, despite settling only two actions in the first half of the year, has already imposed higher penalties on auditors so far in 2024 than in all of 2023.”
Total Actions Initiated Against Auditors: 2018–H1 2024
The new report also examines how five predictions made in the January 2024 publication have fared in the first half of the year. This includes:
- Prediction #1: Overall enforcement activity will remain elevated.
- Prediction #2: Enforcement activity involving PCAOB-registered firms in the People’s Republic of China and Hong Kong will increase.
- Prediction #3: Heightened focus on “audit firm culture” may drive increased enforcement pertaining to systems of quality control, independence, and ethics.
- Prediction #4: PCAOB and SEC enforcement activity will increasingly focus on critical audit matters (CAMs).
- Prediction #5: We may see more joint actions brought by both the PCAOB and SEC.
Enforcement Activity Involving Auditors – 2024 Mid-Year Update also includes a discussion of how developments in the first half of 2024 – including the Supreme Court’s decision in SEC v. Jarkesy and amendments to PCAOB Rule 3502 governing contributory liability – could profoundly impact enforcement activity against auditors moving forward.
The full report can be found on Brattle’s website.
