Consider the following facts:

a$.$ XYZ is a publicly traded company that has been cited three times in the past five years for ethics violations. Its board of directors vetoed an ethics code.

b$.$ The auditors of XYZ are Big $4$ Accounting, L$.$L$.$P$.$

c$.$ The chairwoman of Big $4$ personally knows the chairperson of the PCAOB and verbally informs him that Big $4$ will be auditing XYZ and other publicly traded companies.

d$.$ Big $4$ has a policy to retain working papers of its clients for five years.

e$.$ Recent cost$-$cutting measures at Big $4$ have left Partner Leon Smith as the sole partner on the XYZ audit. Smith has been its auditor for the past $10$ years.

f$.$ XYZ informs Big $4$ that the internal controls that Big $4$ has designed and maintained are working well.

g$.$ Reva Jones, a former partner of Big $4$ who worked on the XYZ audit last year, is now its CEO.

h$.$ In addition to auditing XYZ$,$ Big $4$ does the bookkeeping and taxes for XYZ$.$

i$.$ Frank Washington, also a partner at Big $4,$ specializes in valuation and has been retained by XYZ to value prospective companies that it is considering to take over.

j$.$ Lydia Johnson, another partner at Big $4,$ performs background checks on new employees of XYZ$.$ Fees for this service amount to $3$ percent of all fees that XYZ pays to Big $4.$

k$.$ Last year, XYZ changed its accounting procedures from LIFO to FIFO and restructured its methods for determining the useful lives of its assets.

l$.$ Jack Adams, the corporate attorney for XYZ$,$ is involved in another case that will take much time and has asked his next$-$door neighbor, Smith, to overlook certain issues that are material to the financial statements of XYZ$.$

m$.$ Jones, who just got married, has borrowed money from XYZ to purchase a vacation home in Florida.

n$.$ Two weeks ago, XYZ sold $3$ percent of its shares to an Australian conglomerate that is interested in getting into the U$.$S$.$ market.

o$.$ Smith's wife plays bridge with the wife of the chairman of XYZ$\text{'}$s audit committee. Smith, being overwhelmed by the new laws affecting corporations, asked his wife to let the chairman's wife know of the material changes in certain of XYZ$\text{'}$s accounting policies.

Discuss the Sarbanes$-$Oxley implications on the preceding facts. Cite specific provisions of SOX that are identified. Discuss areas where other violations could occur.