Instead, we would much rather refocus attention on the real issue: audit quality.  While auditor rotation offers one potential means by which to improve audit quality, we want to offer up our own proposed solution to the audit quality dilemma.  Our solution is based on one important assumption: the major international accounting firms will continue to abandon to their “gatekeeper” responsibilities to the investing public, and continue to operate in their own self-interest, as well as that of their bill-paying “clients.”  The result?  Investors will continue to receive more of the same: unqualified “audit” opinions on seemingly GAAP-compliant financial statements of companies with dubious financial health and performance.  Ask yourself a couple questions.  When was the last time you actually saw a “qualified” opinion for a publicly traded company?  Or even an “adverse” or “disclaimer” opinion?  Been awhile, huh? And if you had, would you even have recognized it as something other than a “clean” opinion?  And does it trouble you in the least, that auditors continually manage to issue “clean” opinions, even when companies report material weaknesses in financial reporting?  In the old days, material weaknesses almost certainly triggered at least a “qualified” report…not any more!

Okay, so what do we propose?  We think that any auditor’s report (the current or improved version) should be supplemented with a detailed “audit engagement” report that will allow investors to make up their own minds about the quality of a company’s audit.  Our “audit engagement” report would provide detailed information about the auditor-client relationship (auditor independence), the auditor’s administration of the engagement (supervision, etc.), as well as the qualifications and experience level of the audit team.  Here are some specifics.

Audit Relationship Schedule

This report section would provide readers with insights into relationship issues that potentially could negatively affect auditor independence.

1. How many consecutive years has the current accounting firm served as independent auditor to the company?
2. List audit fees received from the client for each of the past five years, together with an explanation for any increase of 10 percent or more in any one year.
3. List all client personnel previously employed by the current auditing firm together with their previous audit firm position (and whether or not they served on a prior audit team for the client).  Also, for each, report the current job position at the client.
4. List all awards or public recognition of the client levied by the current independent auditor (including tax and consulting services) during the past five years.

Most of the above information can easily be found in publicly available information so a summary disclosure should not be a problem.  Only item 3 as it relates to client personnel may not be disclosed in securities filings ad could be considered “new” information.

Audit Administration Schedule

 Unlike the first section, this portion of our “audit engagement” report addresses potential audit quality issues associated with how the audit is staffed and executed. Since virtually all of this information is NOT publicly available, we expect Big 4 firm resistance to these disclosures to be quite stiff.

1. List engagement hours incurred by each staff level (partner, manager, staff) on the engagement.  The sum should equal total engagement hours.
2. List engagement hours by audit area in descending area (i.e., largest amount of hours to lowest).  The sum should equal total engagement hours.
3. List engagement hours incurred by each staff level (partner, manager, staff) on each audit area identified in number 2 above.
4. Describe audit engagement team turnover for each staff level (partner, manager, staff) for the last two audit years.
5. Describe specific audit areas where audit procedures (e.g., valuation, etc.) have been outsourced to third parties external to the audit firm.  For each item also report the number of hours and cost incurred for the outsourced service.
6. Describe specific audit areas where audit procedures (e.g., confirmations, etc.) have been outsourced to third parties internal to the audit firm (e.g., India or other offices of the firm).  For each item also report the number of hours incurred for the outsourced service. 

While audit firms will argue that the above information is proprietary in nature and potentially could destroy competition, let’s get real.  There is little competition in the large firm audit industry, and their audit product is undifferentiated and homogeneous.  All of the Big 4 essentially audit the same way.  If you need proof, just review the PCAOB’s audit deficiency reports.  By the way, these same reports seem to beg for the information we are suggesting to monitor audit quality.

We believe that the above information will give investors a much better idea of what exactly the auditors looked at and how much effort they expended doing so.  Additionally, if auditors knew that their audit approaches were going to be scrutinized, maybe just maybe, they might begin to evaluate the adequacy of their audit model and detailed procedures.  At a minimum, this information will prove useful to audit committees of the boards of directors, who may not even have thought of asking such questions of their independent auditors.

Audit Education and Experience Schedule

The final piece to our evaluation of audit quality is assessing the engagement team’s education and experience levels.  Hence, the following disclosures.

1. List the average number of years of audit experience possessed by each staff level (partner, manager, staff) on the engagement.  This includes any individuals to whom work has been outsourced and who are internal third parties of the firm.
2. List the percentage of certified public accountants by each staff level (partner, manager, staff) on the engagement. This includes any individuals to whom work has been outsourced and who are internal third parties of the firm.
3. List the percentage of audit engagement team personnel possessing bachelors and masters degrees (one or both) by each staff level (partner, manager, staff) on the engagement. This includes any individuals to whom work has been outsourced and who are internal third parties of the firm.
4. List any engagement team members by each staff level (partner, manager, staff) that have been the subject of any professional disciplinary proceedings or complaints by federal, state, or local licensing authorities as they relate to the practice of accounting, auditing, or tax. This includes any individuals to whom work has been outsourced and who are internal third parties of the firm.
5. List any engagement team members by each staff level (partner, manager, staff) that have been the subject of any disciplinary proceedings or enforcement actions levied by the Securities and Exchange Commission, Public Company Oversight Board, or any other governmental agency (e.g., FDIC, OCC, etc.). This includes any individuals to whom work has been outsourced and who are internal third parties of the firm.
6. For each partner working on the engagement, list the number of unqualified, qualified, and disclaimer opinions issued each year for the past five years.
7. For each partner working on the engagement, list the number of internal control material weakness letters issued each year for the past five years.
8. For each manager and partner on the engagement, list the number of client companies issuing financial statement restatements for the past five years. 

So, that’s it!  Oh, naysayers will comment that our proposal won’t fly either…probably not.  But we can and do hope that the PCAOB might consider some of our suggestions in their ongoing audit report project.  Also, we would like to encourage our academic colleagues not to dismiss it so quickly…give it a second look, after all, think of the great research data sets our proposal would generate.

But if you just can’t seem to buy into our proposal to address audit quality, here is one last suggestion that virtually retains the status quo.  Let’s just rename what we are calling “independent audits.”  Let’s simply call them “GAAP compliance certifications” and drop any pretense of independence or an audit.  Now wouldn’t that save everyone time and money!