The board also spelled out how Deloitte should carry out its activities with any other individuals who draw disciplinary action.
The PCAOB move stems from a board order of Oct. 31, 2008 barring Christopher E. Anderson of Lake Forest, Ill., now 51 years old, and then a partner in Deloitte's Chicago office, from being associated with a registered firm.
However, the PCAOB said Anderson gave advice on the audits for financial statements of three clients during the suspension period. It also charged the firm's Leadership Oversight Committee failed to establish policies and rues for ensuring the suspension was observed and instructed no one at the firm about how Anderson's activities would be monitored. Deloitte says it adopted such procedures on Feb. 2, 2010 and reviewed and clarified them on Aug. 16, 2012.
Anderson had consented to the order, without admitting or denying its allegations. The CPA drew the order from his actions in his role as engagement partner for Deloitte's audit of the fiscal year 2003 financial statements of the Navistar Financial Corp.
In anticipation of the 2008 settlement between Anderson and the PCAOB, Deloitte began the process of removing Anderson from the Chicago audit practice and transferring him to the Audit and Assurances Services Group in its National Office.
However, in his new role, the board said Anderson participated in the development of the firm's quality control policies and procedures. Among those were helping engagement teams understanding their responsibilities and complying with auditing standards, such as those from the PCAOB.
The firm also included Anderson's name in internal directories as a National Office consultation resource on subject matters that related to issuer audits and that included his listing as a resource for consultations related to "Fair Value/Use of Specialists and Fraud – Miscellaneous."
