The Hunger Games of Auditing

Like Katniss Everdeen, the young heroine of the hit movie “The Hunger Games,” auditing leaders are facing their own test of survival.

Summoned to the arena of a hearing room in the nation’s capital last week, witnesses spent two days testifying about the merits and disadvantages of mandatory audit firm rotation by public companies (see PCAOB Hears Pros and Cons of Mandatory Audit Firm Rotation).

Admittedly, the testimony during the Public Company Accounting Oversight Board's roundtable meeting by the leaders of the largest firms and various other experts on the concept of term limits for auditors may not have been as exciting as watching a group of young people fighting for survival in the harsh conditions of a reality TV arena. But the auditing firms could be forced to fight for their survival too if companies are required to change auditors after a specified number of years.

In something akin to the annual “reaping” that takes place in author Suzanne Collins’s best-selling trilogy, the audit committees at public companies would need to choose a new auditing firm every so often or risk sanctions. Like the tributes in the games, firms have come to depend on their sponsors year after year for their gifts of annual fees.

Witnesses at the hearing pointed out that approximately 35 percent of S&P 500 companies have stuck with the same auditing firm for 25 years or more, according to Reuters, and some have stayed with the same firm for more than 100 years, according to the research firm Audit Analytics. Even the Quarter Quell, the super version of the Hunger Games competition celebrated every 25 years to mark the Capitol’s victory over the rebellious districts of Panem, apparently would not have dislodged some of the firms.

One witness at the hearing testified about how firms have effectively operated as “duopolies” in the utility industry and certain other sectors, with only two of the major firms usually winning the jobs (see Big Four Audit Firms Accused of ‘Duopoly’ and PCAOB of ‘Mission Creep’). Katniss Everdeen and her fellow tribute from District 12, Peeta Mellark, might recognize the comparison, contending against a set of “career tributes” who typically win the games year after year.

Still, critics of mandatory rotation were plentiful at the hearing, pointing out that the costs of switching firms are high and it takes a long time for firms to familiarize themselves with the way large, complex companies operate. Many suggested that audit committees need to retain the discretion to appoint auditors, and what is really needed is better expertise on the audit committees.

Like the Gamemakers, audit committee members need to be able to assess the skills of the competing firms in the arena. In Katniss’s case, her hunting skills with the bow and arrow gave her an advantage over the competition, but it was really her perceptiveness and bond with Peeta that counted the most. The same firms that show up year after year to audit the books of the same companies run the risk of getting too complacent and cozy, like the victors of previous Hunger Games who show up annually at the event and spend the rest of their time in the relative comfort of the Victor’s Village in each district.

Mandatory rotation after just a few years is likely to be too stringent a requirement for public companies and their auditors, but a number of the firm leaders and outside experts at the hearings offered constructive suggestions for how auditors and their clients can be made more responsible for improving the quality of audits and enhancing professional skepticism and objectivity.

The PCAOB now plans to organize the feedback it has received so far from the hearings and comments submitted in response to its proposals. The board also now plans to visit several cities around the country to conduct further hearings and roundtables before making its recommendations known. It’s likely to be a long time before we know what the final requirements will be for the auditing firms and their clients in corporate America, but it’s bound to be some variation on the original concept release that may be more or less severe than actually compelling companies to switch auditors every few years.

In a move reminiscent of Panem's evil President Snow, lawmakers in Congress are even threatening to step in with legislation to thwart the PCAOB and ban any requirements for mandatory rotation, most likely at the behest of the influential U.S. Chamber of Commerce, which demanded last week that the PCAOB simply withdraw the concept release entirely.

Like the genetically altered “muttations” created by the leaders of Panem, concept releases can turn out to be very different than originally intended when they evolve into auditing standards. Just as the “jabberjay” was turned into a “mockingjay” by the rebellious districts, the effects on the auditing profession can be similarly unpredictable.

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