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Gabriel Hernandez
Florida International University
MACC Program
BUL 6890
October 12, 2015
Assignment 2: “The Unnecessary Wars”
President Roosevelt once asked Prime Minister Churchill “what this war [WWII] should be
called in future years. Churchill replied that it should be called “The Unnecessary War.” By this,
Churchill meant that had Hitler’s encroachments been met early on (as Churchill had
suggested), there would have been no need to take part in the destructive war which
“consumed all of Europe and encompassed the world.” So, it came to be that WWII did
eventually take place, all because sensible leaders failed to respond to the budding threat—
despite the obvious signs of danger. Had Europe’s leaders been more responsive to the threat,
they could have averted it. Then, all the suffering of WWII would have been prevented. But it
was not, instead, a bad situation was allowed to grow into an unavoidable threat (18).
The same circumstances which gave rise to WWII are representative of the behavior exhibited
in our politics, our economic policy, and ultimately our human nature. No matter how obvious
or predictable a threat may be, regulators and government officials will generally not address it
until it culminates in broad destruction and despair. Examples attesting to this behavior can be
found all throughout history. Most relevant to this assignment are the events which brought
about and the events consequent to the Great Depression of 1929, the Financial Crisis of 2001,
and the Great Recession of 2008.
Subsequent to these catastrophes, sweeping improvements in the regulation of the markets
were implemented. Such improvements were brought about through: the creation of the
Securities Exchange Commission (SEC) with the Securities Acts of 1933 and 1934, the
application the Glass–Steagall Act of 1933, the Sarbanes-Oxley Act (SOX) of 2002, and the
Dodd—Frank Act of 2010. The goal of adopting these regulations was to maintain the stability

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of the financial markets, while improving the public’s confidence in them. Yet, as quickly as
these regulations were implemented, interested parties began to explore ways to undermine
and erode their effectiveness—with varying degrees of success.
The Sarbanes Oxley Act of 2002
During the early 2000s, there were a total of 22 major corporate scandals affecting U.S.
Securities Markets (1). Most notorious amongst these were the scandals involving Enron and
Arthur Andersen. They were the conflicts which sparked the creation of the Sarbanes Oxley Act
of 2002 (SOX) (2). The public’s outrage at these events resulted from Enron’s deceitful measures,
which it employed to deceive the investing community and its own workforce. More scandalous
was the fact that Arthur Andersen, a well-respected and long-standing accounting firm, was
playing both a passive and an active role in Enron’s misleading activities (3). Facing such a large
amount of corporate financial uncertainty, and unable to trust the watchdogs [the auditors]—
who were supposed to remain impartial and objective—investors began to lose faith in the
financial markets, and the accounting profession as a whole.
As a method of dealing with this decline in confidence over the financial markets, the SOX came
into existence (4). It is an act which has had a great impact on our accounting profession. It
increased auditors’ responsibility, liability, and ethical standards. To maintain this higher level
of accountability and to ensure that public company auditors comply with their ethical, legal,
and regulatory obligations, the Public Company Accounting Oversight Board (PCAOB)
continually issues out the new standards which public company auditors must follow. The
PCAOB ensures that public company accounting firms as a whole, and its member CPAs
individually, are performing their duties appropriately. By way of its inspections, it confirms
whether an accounting firm is complying appropriately (4).
If the firm is not performing up to par, the PCAOB has the power of “revocation, or suspension
of an accounting firm’s registration, prohibition from being able to audit public companies, and
imposition of civil penalties” (4). In punishing accounting companies, the PCAOB is free to
collaborate with other governmental agencies. By way of its regulatory requirements, this new
agency imposes a much greater expectation of performance upon auditors (4). With the creation

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of the PCAOB, the accounting profession has stopped the self-regulation trend, and began to
become regulated under an actual “government sponsored organization” (5).
The PCAOB’s independence is what gains it its strength. This independence is what allows it
have the flexibility necessary to enforce SOX regulations. The greatest source of accounting
liability has arisen from SOX Sections 104 and 105. They are powerful because they give the
PCAOB the power to inspect accounting firms, and the consequential ability to punish both the
“accounting firms and accountants.” These sections “give the PCAOB strong oversight powers,”
which is a vast improvement over the PCAOB’s predecessor: the Public Oversight Board (POB)
(5).
Whenever the PCAOB investigates an audit firm, all its employees must cooperate, or risk losing
their registration with the PCAOB. Losing the registration with the PCAOB is a traumatic
experience, as it entails that the firm will be prevented from auditing public companies. Though
this power by itself is a powerful tool, under Section 105(c) (4), the PCAOB also has the power
to impose substantive “civil money penalties” on both individuals and accounting firms (5). In
this system, violations which are deemed intentional are punished much more severely than
those which are not considered intentional (5).
As provided in SOX, auditors of public companies must now deal directly with the established
board of director’s audit committee. No longer does management hire the independent
auditor, the audit contract is now signed with the Board of Directors via the Audit Committee.
Communication between the auditor and the audit committee now becomes a source of
liability as new specific communication requirements are established. For instance, the auditor
must disclose “critical accounting policies to be used,” alternatives available under GAAP, and
“disagreements between auditor and manager” (4).
To limit potential conflicts of interests, audit companies are required to limit the kind of
services they can offer to audit clients. To limit the risk of familiarity, audit partners are rotated
regularly. Finally, an accounting firm is banned from auditing a public company that has
recently hired one of the audit firm’s employees for a role as top official. Most notably, it has
become a felony to destroy audit work papers, or fail to maintain audit records for 5 to 7 years.

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Criminal penalties have also increased for related frauds. In addition, all audit work must be
revised by a second partner, and the audit must contain a “description of internal control
testing” (4). This description of internal control must be thoroughly tested for existence, and
effectiveness. Then it must be reported on. This great amount of new accounting requirements
has the consequence of creating a wide variety of new sources of accounting liability.
“In certain circles, the enactment of SOX is still highly controversial.” At inception, SOX’s
deepest criticismwas that “it would lead to the federalization of corporate law,” because the
law was too overbearing (6). After 13 years of SOX implementation, such an effect has not yet
been noticed. It has also been purported—quite convincingly—that implementing SOX would
overburden U.S. companies with an unsustainable marginal cost, causing many companies to
exit the U.S. public securities market. This too has been disproven. Although some small
companies have exited the securities market, they were either very small or very fraud ridden.
So, implementing SOX has not had as much of an adverse effect as might have been imagined
by some. Still, however slight the effect of the adoption of SOX by the securities market, it is
proper to note that implementation of SOX did have at least some victims (6).
A justifiable criticismof the act is that it has “clear, nontrivial, and quantifiable direct costs” (6).
Though the costs are clear and quantifiable, the benefits are not as clearly defined, and are
potentially impossible to discover because there is no way to accurately measure investors’
confidence in the market. In reply to the objection that costs of compliance with SOX are too
high, one need only recall the vast losses which investors underwent in the years 2000 and
2001, when they lost “between $300 billion and $460 billion” (5). So, while compliance with SOA
certainly has its costs, “these costs are immaterial in relation to the costs which investors had
to bear because of the scandals” (5). There were concerns that implementing SOX would open
the floodgates of litigation. This was disproven. Though during the years of SOX
implementation, litigation and liability insurance costs did increase in the securities markets,
they also sharply declined, and “dropped to pre-SOX levels soon thereafter” (6).
The largest cost, consequently, the area of SOX receiving the highest level of criticismhas been
Section 404. This section “requires both the management of publicly held companies and their

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outside auditor firms to report on the effectiveness of the corporation’s internal controls” (7).
Section 302 requires that the corporation’s CEO and CFO attest to the adequacy of the
corporation’s internal controls, This increased demand in the part of auditors (in compliance
with PCAOB standards), and the fear of criminal charges in the part of executives has meant
that the average public corporation has spent near $4.3 million in order to create the
infrastructure for compliance with SOX. This would be a justifiable source of concern if it were
not also true that year by year compliance costs have decreased at a predictable rate. This is
due to the fact that as the companies’ understanding of their internal control, they begin to
economize upon it (7).
My personal opinion is that SOX is a very appropriate and reasonable act. It appears to put into
law something that is very intuitive to everyone—that an auditor should not be in the business
of auditing his own work. This is just what Arthur Andersen was doing with Enron; it provided
Enron with all of its accounting needs in addition to regular yearly audits. This conflict of
interest was reflected in Arthur Andersen’s revenue from Enron. “Enron paid Andersen $27
million for nonaudit services, compared with $25 million for audit services” (8). So, the conflict
of interest was obvious. In hindsight, it was blind faith in Andersen and the accounting
profession as a whole which stayed investors’ suspicions. When that faith finally dissolved,
action became necessary.
In conclusion, SOX proves to be an excellent legislature. It has accomplished its goal of once
again bringing confidence to the financial markets. It has also strengthened the perception of
the accounting profession. Using the PCAOB as its enforcer, it keeps accounting professionals
from losing their objectivity. Coupled with the high ethical standards which the profession
enforces upon itself, the Sarbanes Oxley Act of 2002 creates an environment of justifiable
respectability for the profession, and should instill pride in us as professionals in the field.

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The Dodd Frank Wall Street Reform and Consumer Protection Act of 2010
The Dodd Frank Wall Street Reform and Consumer Protection Act of 2010 was created to
address the risks which led up to the financial crisis of 2008 (9). It is meant to bring “our broken
financial regulatory system” up to speed, so that a crisis like the one suffered in 2008 will not
repeat (10). The Dodd-Frank Act is meant to “prevent the excessive risk taking that led to the
financial crisis” (10). These rules are meant to permanently stabilize the financial markets, and to
promote an economy where healthy growth is possible. It is composed of 16 provisions, some
of which are more controversial than others. The Volker Rule (Title VI) is among the most
controversial of the Dodd-Frank provisions. The Volker Rule “imposed a prohibition on most
proprietary trading by U.S. banks and their affiliates” (11). It also restricts banks from dealing in
hedge funds.
The act is a massively ambitious enterprise. It is massive in regulation requirements, counting
more than 1000 pages of legislation, and it is receiving massive opposition from interested
parties. One criticismis that it is overly-complex in order for it to be practical to implement (12).
Its strongest opponents are the leaders of Wall Street—the bankers. The criticism of Dodd
Frank may not be without merit; an act which is overly complex and over-reaching has a high
risk of failing. However, the fact that the strongest and most eloquent opponents to the act are
the people it is aimed to regulate must not be taken for granted. Regardless of Dodd-Frank’s
shortcomings, it is the tool which the government has for the necessary task of Wall Street
reform (12).
Unfortunately, it appears that in seeking compromise, and due to hash opposition in congress,
what would have been effective legislation may have been perverted into a large, redundant,
impotent legislation. Though critics have much to say against the redundancies of the Dodd-
Frank Act—how the new institutions created by the act will operate or how they will be
funded—the largest source of concern lies somewhere else. The critics fear that “the Dodd-
Frank apparatus will smother financial institutions in so much red tape that innovation is stifled
and America’s economy suffers” (13). This seems like a sensible concern, as it is justified by the
lack of clarity in the act itself.

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Despite all the gloomy outlooks in the part of critics, there is no guarantee that the Dodd-Frank
Act will be a failure. Similar criticismwas directed at SOX, despite it, SOX has turned out very
well. Besides, the alternative—rampant deregulation—is not very attractive. We have already
witnessed that deregulation of the markets led to a financial bubble, and a financial crisis. The
sensible alternative is to begin regulating the financial system. At best, America will experience
a new era of stability and prosperity. At worst, we will make new mistakes, but it is better that
we make some new mistakes than to simply repeat old ones. As long as Dodd-Frank is not
sabotaged just as it is about to spread its wings, it may still have the opportunity to succeed.
Dodd-Frank deals with a variety of concerns, among them are aspects of “corporate
governance, financial transactions, executive compensation, disclosures, and whistle blower
protection” (14). This means that accounting consequences for the act are unavoidable. When
considering Asset Backed Securities (ABS), Dodd-Frank proposes that the banks which create
these instruments must be prevented from hedging the risk arising from them. Having some
“skin in the game” should make financial institutions less willing to take unnecessary risks. Such
policies will surely lead to changes in accounting policies (14).
Where a bank used to securitize the loans it distributed to customers, and then sell the loan on
the open market, such behavior would not be allowed under Dodd-Frank. This is a restriction
which resulted directly as a response to the financial crisis, which was largely caused by the
proliferation of ABSs. The accounting consequence of such an event is that a more thorough
risk assessment must be made by the auditors. Where these assets were viewed and recorded
as short-term investments that would be sold within a year, they retain the form of long term
investments, lasting for the length of the life of the loan. Auditors must ensure this new
requirement is respected (14).
Every Dodd-Frank provision is made out to seem quite controversial, but to me it seems
prudent and appropriate. The act also intends to influence executive compensation structures;
it requires more disclosure of executives’ compensation, and aims “to prohibit certain incentive
compensation arrangements” (14). The role of the accountant will be to adequately disclose
each compensation arrangement. This will be a very sensitive matter, and dealing with it will

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require much tact in the part of the auditor. The increased sensitivity of this matter arises from
the fact that the executive officer may very well be the auditor’s true employer.
Though in principle, the board of directors should be relatively independent from the executive
branch, and that the audit committee should be impartial, in practice, this is not always
necessarily the case. In practice, management often remains a dominant figure which exerts
influence over the board. So, this Dodd Frank requirement places the auditor in a tough
situation. He is put in a situation where he must delve deeply into the secrets his employer
probably wishes to remain confidential, and unknown to the public. In addition, the auditor will
have to ensure that incentive pay which was paid as far as three years prior was appropriately
earned; I hold this as the tensest moment of the audit.
After executive compensation, the Volcker rule, is the most controversial regulation, it certainly
is the most discussed. The notoriety of the Volcker rule is due to the fact that the Volcker rule
prevents banks from participating in securities trading, and from investing in “hedge and
private equity funds.” The controversy over such dramatic changes stems in part from the fact
that banks will lose big chunks of revenue. “These plans may force companies to restructure,
including downsizing.” Downsizing will mean selling “parts of their businesses in order to
comply with the regulations” (14). Such restructuring will create a lot of additional work for
accountants. Since the firm’s profitability will be affected by such restructuring, accounting risk
must be reassessed. But this is just one aspect. The taxation of the business must also be re-
evaluated, along with calculations for the disposal of equipment, and transfer pricing
considerations.
Though these measures may seemDraconian at first glance, upon consideration, they make
sense. If the aim of Dodd-Frank is to eliminate institutions which are too big to fail, the only way
of achieving these goals is to reduce the company both physically and practically. Had the great
recession of 2008” (15) not occurred, or had these institutions been indeed allowed to fail, or
had these institutions not accepted government aid, there may have been no need to resort to
Draco. As things stand, in order to prevent a repetition of the great recession, or another loss of
confidence in the markets, these measures prove to be appropriate.

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Due to the threat Dodd-Frank possess to large banks, there is a mountain of opposition to the
enforcement and creation of its regulations. Possessing much influence in congress, bills have
been put to congress in an attempt to subvert Dodd-Frank regulations. In January 2015, a bill
was introduced to the house under the pretense that it was just a technical adjustment. If
accepted, it would have altered “nearly a dozen provisions of the 2010 Dodd-Frank financial
reform law, loosening regulation of Wall Street Banks” (15). The intent of the bill was to “delay
the Volcker Rule… water down rules on private equity firms… loosen rules on derivatives…
weaken transparency rules” (15). Luckily the bill was not passed.
Such a crass attempt at legislation came quickly after December 2014, when banks had been
given a two year extension to comply with the Volcker Rule. This extension allowed banks to
postpone their trading in collateralized loan obligations until 2019. Obviously, in attempting to
pass his bill, Rep. Michael Fitzpatrick (R-Pa.) was attempting to be circumspect. He attempted
to sneak the bill in as if it were a series of mere adjustments to the bill, hoping the true nature
of the bill would be unnoticed. The attempt failed (15).
This behavior in the part of the GOP is indicative of their overall strategy to repel Dodd-Frank
altogether. Their strategy consists of chipping “away along all possible dimensions, using a
combination of legislation and pressure on regulators” (16). This strategy has the apparent goal
of delaying the implementation of the Volcker Rule for as long as possible, while it attaches
amendments to sections of the Dodd Frank Act to essential legislature like budget plans. All
this, till the opportunity to repel Dodd Frank all together finally presents itself. Ultimately, the
state of events could be such that by “November 2016, a republican president will work with a
Republican Congress to eliminate all parts of Dodd-Frank” (17).
Like the Sarbanes Oxley Act of 2002, the Dodd-Frank Act of 2010 makes a lot of sense. At least
one difference with Dodd-Frank is that the opposition is more boisterous and has infinitely
greater resources. In addition, the changes implemented by Dodd-Frank are very big changes
for any business to voluntarily accept. So, stout resistance should be expected.
Having explored SOX and Dodd-Frank acts, exploring their varying degrees of success, and
analyzing the viewpoints of opposition, I no longer find myself very critical of legislators who do

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not prevent a danger, despite knowing that it is an eminent danger. I wrote that the Great
Depression could have been averted, but this would only be possible in Plato’s republic, where
the rulers are rational and benign. In a democracy, catastrophes must be allowed to occur. But
allowing implies there is something one could have done about it. The reality is that one really
can’t prevent an economic catastrophe in America. Suppose it is 1929, and the Great market
crash just occurred, but instead of letting the market crash and allowing millions of people to
suffer, the government organized a bailout right away, like it did recently. The question is
whether congress would be motivated to pass the securities acts of 1933 and 1934, and the
Glass–Steagall Act. I believe it would not.
In order for sweeping regulation to be effective, the economy must necessarily hit rock bottom.
Returning back to our own time, Dodd-Frank will fail because the banks were bailed out. Had
the banks been allowed to fail, and had the economy been placed on its head, Dodd-Frank
would have had a better chance at success. The nation did not hit rock bottom. Though things
got bad, they did not get bad enough to inspire sweeping change. Perhaps, sweeping reform
will have a better chance next time, if we hit rock bottom that is. Of course, I hope such
catastrophes will be avoided, but history has a nasty habit of repeating itself as human nature
continues to prevail over reason.

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Footnotes
1 The Corporate Scandal Sheet(Forbes)
http://www.forbes.com/2002/07/25/accountingtracker.html
2 Understandingthe Sarbanes-OxleyActandCorporate Fraud (About.comMoney)
http://bizfinance.about.com/od/smallbusinessfinancefaqs/a/sarbanes-oxley-act-and-enron-
scandal.htm
3 The Falloutof Arthur AndersenandEnrononthe Legal Landscape of AmericanAccounting(HG.org
Legal Resources)
http://www.hg.org/article.asp?id=31277
4 How the Sarbanes-OxleyActof 2002 Impactsthe AccountingProfession(How the Sarbanes-Oxley
Act of 2002 Impactsthe AccountingProfession)
http://www.dgm.com/information-center/sarbanes-oxley-information/how-the-sarbanes-oxley-act-
of-2002-impacts-the-accounting-profession
5 Impact of the Sarbanes-OxleyActonAccountantLiability(Impactof the Sarbanes-OxleyActon
AccountantLiability)
http://www.webpages.uidaho.edu/wegman/JerryWegmanPapers/Wegman-aleri-award-
website.htm
6 Lookingat the Costsand Benefitsof SOX|The D&O Diary(The DO Diary)
http://www.dandodiary.com/2014/03/articles/sox-generally/looking-at-the-costs-and-benefits-of-
sox/
7 The Gain AndPainOf Sarbanes-Oxley(Forbes)
http://www.forbes.com/2005/12/29/microsoft-guidant-sox-in_cc_1230soapbox_inl.html
8 Were Enron, AndersonTooClose ToAllow AuditortoDo Its Job?(WSJ)
http://www.wsj.com/articles/SB1011565452932132000
9 What isthe Dodd-FrankAct?How doesit affectme?(Investopedia)
http://www.investopedia.com/ask/answers/13/dodd-frank-act-affect-me.asp
10 Wall StreetReform:The Dodd-FrankAct(The White House)
https://www.whitehouse.gov/economy/middle-class/dodd-frank-wall-street-reform
11 The Dodd-FrankAct: a cheatsheet(MorrisonFoerster)
http://media.mofo.com/files/uploads/images/summarydoddfrankact.pdf
12 Is Dodd-FrankTooComplex toWork?(The HuffingtonPost) By:Ashkenas,Ron.
http://www.huffingtonpost.com/ron-ashkenas/finance-regulation_b_1344686.html
13 Too bignot to fail (The Economist)
http://www.economist.com/node/21547784
14 The Dodd-FrankAct: Couldthere be AccountingConsequences?(KPMG)
https://www.kpmg.com/Global/en/IssuesAndInsights/ArticlesPublications/Documents/dodd-frank-
accounting-implications.pdf
15 The House just passeda GOPbill wipingoutWall Streetreforms(MotherJones)
http://www.motherjones.com/politics/2015/01/dodd-frank-bill-house-gop-hr-37
16 The RepublicanStrategytoDeregulate Wall Street|BillMoyers.com(BillMoyers.com)
http://billmoyers.com/2015/01/08/republican-strategy-repeal-dodd-frank/
17 The RepublicanStrategyToRepeal Dodd-Frank(The BaselineScenario)
http://baselinescenario.com/2015/01/07/the-republican-strategy-to-repeal-dodd-frank/

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18 What DidChurchill Meanby "UnnecessaryWar"?(WhatDid Churchill Meanby"UnnecessaryWar"?)
http://www.scottmanning.com/archives/unnecessarywar-whatdidchurchillmean.php

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References
 How the Sarbanes-OxleyActof 2002 Impactsthe AccountingProfession(How the Sarbanes-OxleyAct
of 2002 Impactsthe AccountingProfession)
http://www.dgm.com/information-center/sarbanes-oxley-information/how-the-sarbanes-oxley-act-
of-2002-impacts-the-accounting-profession
 Impact of the Sarbanes-OxleyActonAccountantLiability(Impactof the Sarbanes-OxleyActon
AccountantLiability)
http://www.webpages.uidaho.edu/wegman/JerryWegmanPapers/Wegman-aleri-award-website.htm
 Is Dodd-FrankTooComplex toWork?(The HuffingtonPost) By:Ashkenas,Ron.
http://www.huffingtonpost.com/ron-ashkenas/finance-regulation_b_1344686.html
 Lookingat the Costsand Benefitsof SOX|The D&O Diary(The DO Diary)
http://www.dandodiary.com/2014/03/articles/sox-generally/looking-at-the-costs-and-benefits-of-
sox/
 The Corporate Scandal Sheet(Forbes)
http://www.forbes.com/2002/07/25/accountingtracker.html
 The Dodd-FrankAct: a cheatsheet(MorrisonFoerster)
http://media.mofo.com/files/uploads/images/summarydoddfrankact.pdf
 The Dodd-FrankAct: Couldthere be AccountingConsequences?(KPMG)
https://www.kpmg.com/Global/en/IssuesAndInsights/ArticlesPublications/Documents/dodd-frank-
accounting-implications.pdf
 The Falloutof Arthur AndersenandEnrononthe Legal Landscape of AmericanAccounting(HG.org
Legal Resources)
http://www.hg.org/article.asp?id=31277
 The Gain AndPainOf Sarbanes-Oxley(Forbes)
http://www.forbes.com/2005/12/29/microsoft-guidant-sox-in_cc_1230soapbox_inl.html
 The House just passeda GOPbill wipingoutWall Streetreforms(MotherJones)
http://www.motherjones.com/politics/2015/01/dodd-frank-bill-house-gop-hr-37
 The RepublicanStrategytoDeregulate Wall Street|BillMoyers.com(BillMoyers.com)
http://billmoyers.com/2015/01/08/republican-strategy-repeal-dodd-frank/
 The RepublicanStrategyToRepeal Dodd-Frank(The BaselineScenario)
http://baselinescenario.com/2015/01/07/the-republican-strategy-to-repeal-dodd-frank/
 Too bignot to fail (The Economist)
http://www.economist.com/node/21547784
 Understandingthe Sarbanes-OxleyActandCorporate Fraud (About.comMoney)
http://bizfinance.about.com/od/smallbusinessfinancefaqs/a/sarbanes-oxley-act-and-enron-
scandal.htm
 Wall StreetReform:The Dodd-FrankAct(The White House)
https://www.whitehouse.gov/economy/middle-class/dodd-frank-wall-street-reform
 Were Enron, AndersonTooClose ToAllow AuditortoDo Its Job?(WSJ)
http://www.wsj.com/articles/SB1011565452932132000
 What DidChurchill Meanby "Unnecessary War"?(WhatDid Churchill Meanby"UnnecessaryWar"?)
http://www.scottmanning.com/archives/unnecessarywar-whatdidchurchillmean.php
 What isthe Dodd-FrankAct?How doesit affectme?(Investopedia)
http://www.investopedia.com/ask/answers/13/dodd-frank-act-affect-me.asp

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