In lieu of a full investigation under the Joint Ethics Enforcement Program, this case was resolved by a settlement agreement, effective November 2, 2018.
Information came to the attention of the Ethics Charging Authority (ECA) (AICPA Professional Ethics Executive Committee and Connecticut Society of CPAs Professional Ethics Committee) that indicated that on February 26, 2016, Ms. Halpern agreed to an Offer of Settlement before the Securities and Exchange Commission (SEC). Without admitting or denying the findings, Ms. Halpern was issued a cease and desist order by the SEC, suspended from appearing or practicing before the SEC for one year, and ordered to pay disgorgement of $13,000.
In consideration of the ECA forgoing further investigation of ’s conduct as described above, and in consideration of the ECA forgoing any further proceedings in the matter, agreed as follows:
- To waive rights to further investigation of this matter in accordance with the Joint Ethics Enforcement Program (JEEP) Manual of Procedures.
- To waive rights to a hearing under AICPA bylaws section 7.4. and the bylaws section X.
- To neither admit nor deny the above specified charges.
- To the AICPA and the from the effective date of this agreement.
- To comply immediately with professional standards applicable to the professional services performs and to submit evidence of such compliance.
- To complete the following continuing professional education (CPE) * within months of the effective date of this agreement and provide evidence of such completion (e.g., attendance sheets, course completion certificates, etc.).
Audit Workpapers: Documenting and Reviewing Field Work—8.5 hours
GAAS: A Comprehensive Review for Auditors—11.5 hours
- To comply with directive e. above, submit, months after completion of the , a list of the highest level (audits, reviews, and compilations with note disclosures) of engagements that performed in the month period following the date completed the . The following information should be included regarding the engagements listed:
- Total hours spent on each engagement
- Her role and hours on each engagement
- Level of professional services rendered
- Type of report issued
- Type of organization
- Whether it was an initial engagement
The ECA will select one of these engagements for review. will be informed of this selection and will be asked to submit information to include a copy of report, the financial statements, and working papers related to that engagement for review by the ECA. The ECA may extend the period to select an engagement to ensure a suitable selection is available. A peer review undergone by firm would not exempt from this requirement.
agrees to inform the ECA of any changes in the composition of practice, changes in role or if has not performed any audits, reviews, and compilations with note disclosures, until a suitable work product is selected for review. If practice changes and is no longer involved with audits, reviews, and compilations with note disclosures, no longer acts in a supervisory capacity on such engagements or has not performed such engagements during the above specified period, must inform the ECA of this change and the ECA may require that attest every six months for three years as to the nature of practice. If, during the three-year attestation period, returns to performing such engagements, must inform the ECA of this change and the ECA will select a suitable work product for review.
After an initial review of such report, financial statements, and working papers, the ECA may decide has substantially complied with professional standards and close this matter. Or, the ECA may decide that an ethics investigation of the engagement submitted is warranted. If, at the conclusion of the investigation, the ECA finds that professional standards have in fact been violated, the ECA may refer the matter to the AICPA Joint Trial Board for a hearing or take such other action as it deems appropriate.
- This prohibition will remain in effect until the ECA determines that the work product submitted to comply with directive ., above, substantially complies with professional standards. This prohibition will be communicated to peer review oversight agency.
- To be prohibited from serving as a member of any ethics or peer review committee of the AICPA and the until has completed all directives in this letter. This prohibition will be communicated to those responsible for appointments to such committees. In addition, if applies to join any other committee of the AICPA or the , must inform those responsible for such appointments of the results of this ethics investigation. This prohibition shall remain in effect until the ECA determines that the work product submitted to comply with directive ., above, substantially complies with professional standards.
- To be prohibited from teaching continuing professional education courses approved by the AICPA or the state CPA societies in accounting and auditing until has completed all directives in this letter. This prohibition will be communicated to those responsible for engaging CPE instructors at the AICPA and the . This prohibition shall remain in effect until the ECA determines that the work product submitted to comply with directive ., above, substantially complies with professional standards.
- That the ECA shall provide a copy of this settlement agreement to the AICPA’s Peer Review Division staff, peer review administering entities and firm’s peer reviewer.
- That the ECA shall publish name, the charges, and the terms of this settlement agreement.
- That the ECA shall monitor compliance with the terms of this settlement agreement and initiate an investigation where the ECA finds there has been noncompliance.