Articles, Papers, and Presentations in Professional Ethics

Comment Letter to the Securities and Exchange Commission on IFRS Convergence (2008)

The letter I sent to the SEC on its “Roadmap to IFRS Convergence,” which gained the attention of members of the NASBA (National Association of State Boards of Accounting) and FASB (Financial Accounting Standards Board), and led to an invitation to give a seminar on accounting professionalism for the FASB.

Comment Letter to the PCAOB (with Mark Cheffers) on Mandatory Auditor Rotation (2012)

An argument against mandatory auditor rotation, on two grounds: (1) empirical, that the best evidence suggests that rotation will improve audit quality only marginally, at significant cost, while resulting in an even greater, albeit temporary, loss in audit quality; (2) conceptual and historical, that mandatory auditor rotation will not address the true issues of auditor independence, and will have potentially a detrimental effect on accounting professionalism.

Reply to Karpoff et al. (2012), ‘A Critical Analysis of Databases Used in Financial Misconduct Research’

A defense of the Audit Analytics Restatements Database against some fairly ham fisted criticisms.

Comment Letter to the Securities and Exchange Commission on Amendments to Regulation D, Form D

An argument that the issuer’s auditor should be identified in the SEC form for a private placement.

Audit Analytics, Disclosure Control Briefing

The white paper at Audit Analytics which gives an outline of the Disclosure Control database, which was one of the projects I have worked on as Senior Research Analyst and Public Policy Consultant for the Ives Group.

Some fundamental concepts of professional ethics for accounting (2009)

Slides for a presentation at the American Accounting Association national convention in New York City.