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May 06, 2016


Herb Chain

Clearly, the APA was generated by egregious alterations of working papers to be subject to inspection. You are right that the concept is fundamental to law and professional standards. Inspections must have revealed significant noncompliance to warrant such a release.

Professional standards allow changes to working papers after the release of the report, if properly documented (as you note). Typically, this would result from omitted procedures, possibly resulting from an inspection deficiency (PCOAB, Peer Review, or internal).

And, again as you note, the cover up is often worse than the crime.

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