You are a partner in the professional ethics division of your firms national office, responsible for investigating possible ethical violations by your firms personnel. You just finished reading news reports that the PCAOB and SEC are investigating an alleged audit failure by your firm in its audit of Futuristic Technologies Incorporated (FTI) for the year ended December 31, 2019. To make matters worse, FTI fired your firm as its auditor, hired another auditor and restated its 2018 and 2019 financial statements to correct what it agreed were material errors.

You expected these news reports because you have been investigating the matter internally for the past several weeks, after the regulators had contacted the firms leadership seeking cooperation in their investigations.

During your investigation you interviewed the firms professionals involved in the two professional engagements. Among other things you discovered the following:

• 2019 was the first year your firm audited FTIs financial statements. The predecessor auditor was a well respected, but smaller, regional firm.

• During the 2018 audit, the predecessor auditors had a difference of opinion with FTI management as to how certain material transactions should be accounted for in FTIs financial statements. FTI hired your firm on a consulting basis to provide analysis and advice on how the transactions should be accounted for. Your professionals agreed with FTI management. The previous auditor eventually agreed to allow the accounting and issued an unmodified audit report on the 2018 financial statements.

• In part because of FTIs satisfaction with the accounting advice provided in the consulting engagement, FTI hired your firm to audit its financial statements for the year ending December 31, 2019.

• The error correction and restatement of the financial statements in 2020 was primarily related to the transactions on which your firm had provided the consulting services and which were OKd during the 2019 audit.

• Bill Montgomery an audit partner with your firm, and FTIs chief financial officer, Audrey Fernandez, were members of the same country club and golfed together and socialized on a periodic basis. It was Montgomery who suggested to Fernandez in early 2019 that she hire your firm to provide the consulting services in connection with the accounting disagreement during the 2018 audit.

• The firm assigned Montgomery as the audit partner on the 2019 audit because of his relationship with Fernandez, despite the fact that Montgomery had no experience in FTIs industry.

• Montgomery expressed his concern about his lack of industry experience to the managing partner of his office. The managing partner insisted that Montgomery accept the new engagement, saying, You know as well as I do, Bill, that we dont have anyone else available to do this audit. The firm addressed his lack of industry experience by assigning two senior audit managers to the audit, only one of which had experience auditing companies in FTIs industry.

• The two senior managers were from two different offices of the firm because Montgomerys office audit staff was already overbooked. Montgomery had worked with neither of these senior managers before the 2019 audit.

• During the audit, one of the senior managers came to believe that the accounting for the transactions was not correct and suggested further discussion with the national office. After an intense discussion with Montgomery, the senior manager became concerned that his career with the firm would end if he continued to disagree. He dropped the matter. The firms senior leadership has asked you to prepare a confidential memorandum, addressed to them, that identifies possible ethical violations and the specific facts related to each of the possible violations.