1、審計實施上的第二個轉變，是越來越強調“審計基礎風險”。審計的基礎風險的增大與審計任務的數(shù)量的增大成正比，這是合理的，這種假設是合乎邏輯的。但是，審計專家是可以確定一家公司的經(jīng)營業(yè)務中，最危險的那個部分的。不幸的是，安然公司和其他企業(yè)的倒閉，已經(jīng)表明，一些審計者沒有辦法充分的確定，公司業(yè)務的經(jīng)營運作中，哪個部分會遭受著最大的風險。此外，審計者采用基本風險的方法，有可能無法發(fā)現(xiàn)欺詐活動。雖然這一會計師審計獨立性的新概念，對于某種環(huán)境下的某個審計者，可能是適合的，但往往審計者會努力去用欺騙性的會計數(shù)字，幫助隱瞞經(jīng)營狀況，從而隱瞞真實的經(jīng)濟業(yè)績。在20世紀90年代，似乎有些審計者會忽視他們的最直接的責

2、任，而按照第三方投資者的利益去行動。加強會計師審計的獨立性 法律上禁止擔任審計工作的會計師與委托人在財務上有經(jīng)濟利益關系，是美國從20世紀30年代直至20世紀90年代期間，會計師審計獨立性原則存在的基礎。但這并不代表這在英國或其他一些國家也是同樣正確，即使禁止金融利益上的連帶關系，通常是實際中按照最基本的會計制度中留心觀察，就可以得出的結論性做法。 實際上，目前，禁止擔任審計工作的會計師擁有客戶的財務利益幾乎是一個普遍性的原則。美國證券交易委員會和公共會計行業(yè)都不約而同的把的他們大部分的注意力，重點地放在，會計師審計的獨立性概念的界定，和對財政利益的禁令的執(zhí)行上。詳細的規(guī)則和報告結構已制定的出

3、來了，目的是為了要揭露，任何一個會計師事務所的職業(yè)雇員，所可能擁有的經(jīng)濟利益，也包括這些職業(yè)雇員的配偶，父母，或他們的孩子。上市公司會計監(jiān)管委員會采用了這些規(guī)則中的一大部分，這在一定程度上緩和了那些制度上有不合理地方的地區(qū)的問題。除此之外，還有輪換任用的審計方法。在某些國家，如意大利，審計者可以對委托人執(zhí)行某一個特定年限的審計工作。這種類型的管理方法，在美國和英國，從來沒有被認真的考慮過。雖然法案要求，個別審計者要定期地輪換委托人客戶。而在法國，會計師審計的輪換概念是顛倒的：即審計者的任期為一段固定的時間，在這段時間里，他們不能被取代。這種規(guī)則的制定，目的是增加會計師審計的獨立性，因為由此審計

4、者對于被客戶解雇的擔憂就減少了。 關于會計師審計獨立性的標準，上市公司會計監(jiān)管委員會通過了臨時準則3600T作為其規(guī)章制度。第3600T準則如下： 任何有關審計報告的籌備或發(fā)布的，已經(jīng)登記的注冊會計師事務所及其所有相關人員，都應遵從獨立性標準： （一）依照美國注冊會計師協(xié)會的專業(yè)行為守則第101條所描述的，依照裁決的特殊解釋除外，在2003年4月16日美國注冊會計師協(xié)會專業(yè)標準，東部部分101條和191條（美國注冊會計師協(xié)會2002）的范圍內，是不能取代或修正的； （二）標準第1號、第2號、第3號，及解釋中的99-1，00-1和00-2，在獨立準則委員會的范圍內，不能取代或修正。 從本質上來說

5、，上市公司會計監(jiān)管委員會已經(jīng)認識到以前制定的會計師審計獨立的標準，被美國注冊會計師協(xié)會和美國證券交易委員會，通過獨立標準委員會，又進一步的發(fā)展了。對會計師審計獨立性的重新思考我們現(xiàn)在需要的，是一個完整的對于會計師審獨立性概念的重新思考。這種復議可能帶來一種會計師審計獨立性的新概念，它是基于重申專業(yè)的會計標準的客觀性和中立性極其道德規(guī)范上的，而不是主張站在委托人、客戶的立場上。考慮到一些最近和正在發(fā)生的會計和審計丑聞，顯然，會計師審計的獨立性不應該站在客戶的立場上。 這種觀點要求，會計師審計的獨立性的新概念要結合具體的主張來實施：（1）審計者不應該提倡擁護他們的客戶；（2）管理者不能影響查賬公費

6、，即審計費用和會計師審計的范圍。如果沒有過渡到這一概念，會計師審計的獨立性的標準，將極有可能只是做做門面功夫，根本不足以保證審計者在實際中獨立于委托人管理者而存在。The Varying Concept of Auditor IndependenceShifting with the Prevailing Environment，C. Richard BakerAUGUST 2005 - As CPA Journal Editor-in-Chief Robert Colson observed in his March 2004 column, “Auditor Independence Re

7、dux,” the concept of auditor independence has varied over the last 150 years. In a general sense, auditor independence has borne a relationship to the prevailing commercial environment in different time periods. There has not, however, been a clear transition from one concept of auditor independence

8、 to another. Frequently, more than one idea of auditor independence has been present in the discussion about independence between professional accountants and auditors, regulators, and the general public.The initial concept of auditor independence, which arose during the 19th century, was based on t

9、he premise, primarily British in origin, that a principal duty of professional accountants and auditors was the oversight of absente investments in the existing and former colonies of the British Empire. During this period, a relatively small number of accounting firms could perform audits for a rel

10、atively large number of entities. Professional accountants and auditors could render reports on the financial performance of different entities and could work for different investor groups.The concept of auditor independence during this era did not conceive of auditors as advocates for audited entit

11、ies; British investors explicitly forbade auditors from investing or working in the businesses that they audited. At the same time, as long as auditors maintained their primary loyalty to the investors back home, the scope of professional accounting services could be reasonably broad. For example, a

12、uditors were permitted to keep the books and prepare the financial statements for the entities they audited.This initial concept of auditor independence changed during the late 19th and early 20th centuries. During this time, there was an economic shift from capital coming primarily from foreign sou

13、rces to capital deriving primarily from domestic sources. This change was associated with the emergence of large American corporations in industries such as mining, railroads, energy, and telegraph and telephone. The emergence of large American corporations was accompanied by a change in the underst

14、anding of the purpose and nature of the business corporation. In the 1930s, noted economists Adolf Bearle and Gardiner Means articulated this change by advancing the proposition that large corporations were based on the separation of ownership from management and that an important role for accountin

15、g and auditing was to properly value the proprietary interest of the corporation. In the context of this new idea of the corporation, the auditors primary duty was to serve the needs of the collective proprietary interest rather than a specific absentee-ownership interest. This collective proprietar

16、y interest essentially comprised domestic shareholders, that were often large banks or wealthy investors, but increasingly the general public has become involved in stock ownership.In contrast to the professional and economic arguments for auditor independence, R.W. Bartlett, in “A Heretical Challen

17、ge to the Incantations of Audit Independence” (Accounting Horizons, vol. 5, No. 1, 1991), suggested that auditing is a sort of ceremony involving incantations about independence. Bartlett argued that there have been four kinds of “incantations” regarding auditor independence:The “smoking gun.” This

18、is the argument that only in a few documented instances has auditor independence been found to be implicated in audit failures, at least if one accepts the evidence provided by lawsuits and prosecutions of auditors for securities fraud. Most lawsuits and prosecutions of auditors have been based on a

19、ssertions of incompetence or lack of due diligence in the application of auditing standards, rather than lack of independence. An inability to obtain access to detailed records of lawsuits and other evidence about audit failures, however, makes this incantation difficult to prove. “We are doing pret

20、ty good.” Based on public opinion surveys, the public accounting profession has generally been held in high regard. Public opinion polls assessing the esteem of the profession often address issues like objectivity, reliability, and honesty, rather than independence perse. While objectivity, reliabil

21、ity, honesty, and independence may overlap, what “independence” actually means to the general public is unclear. Often, the public is not well informed about what auditors do. The “public good.” This incantation suggests that if too many constraints are placed on the public accounting professions sc

22、ope of services, accounting firms will be unable to serve clients properly, thereby imposing significant costs on the public. Some public accounting firms have argued that providing nonauditing services allows them to perform better audits because they can obtain a better understanding of the client

23、s systems. “Trust us.” Independence is often said to be a mental state possessed by professional accountants and therefore not subject to empirical observation or quantification. This incantation is based on the idea of auditor economic self-interest; that is, auditors are assumed to maintain indepe

24、ndence and objectivity so as not to harm their longer-term economic interests. This assumes that auditors continually evaluate the costs and benefits associated with ethical behavior and always resolve conflicts in favor of behaving ethically because doing so produces the greatest long-term economic

25、 benefit. While these assumptions may be argued, it can also be observed that the individual economic calculus of a particular auditor may weigh in favor of retaining an important client rather than being objective and independent, thus undermining the “trust us” argument. Changes in the Market That

26、 Affected Auditor IndependenceJonathan Weil, in “Behind Ways of Corporate Fraud: A Change in How Auditors Work” (The Wall Street Journal, March 25, 2004), suggests that during the 1970s and 1980s the market for audit services and the way in which audits were conducted changed, contributing to a decl

27、ine in auditor independence. The first component of change was price competition. Prior to the 1970s, the AICPA Code of Conduct prohibited auditors from publicly advertising their services, from making uninvited solicitations to rival firms clients, and from participating in competitive bidding for

28、audits. Under threats of antitrust action by the federal government, the AICPA was compelled to remove these prohibitions against competitive practices. As a result, competitive bidding in auditing became commonplace.The second change in how audits were conducted was an increased emphasis on “risk-b

29、ased auditing.” Risk-based auditing is reasonable in that the largest amount of audit effort is placed on the greatest areas of audit risk. This logical idea assumes, however, that auditors are experts in determining the riskiest areas of a companys operations. Unfortunately, as Enron and other busi

30、ness failures have demonstrated, some auditors are not sufficiently able to determine which areas of a companys operations are subject to the greatest risks. In addition, auditors using a risk-based approach might not detect fraudulent activities. While this new concept of auditor independence may b

31、e appropriate for an auditor in certain circumstances, too often an auditors efforts to aid management resulted in misleading accounting numbers that concealed true economic performance. During the 1990s, it appeared that some auditors neglected their most immediate responsibility to act on behalf o

32、f third-party investors or, at a minimum, to be an objective and neutral interpreter of accounting standards.PreSarbanes-Oxley Proposals to Enhance Auditor IndependenceA legal prohibition against an auditor possessing a financial interest in a client has been the cornerstone of auditor independence

33、rules in the United States since the 1930s. Until the 1990s, this was not necessarily true in the United Kingdom and some other countries, even though prohibitions against holding financial interests were generally observed in practice because of the standards of the accounting institutes and common

34、 law. Currently, a prohibition against auditors possessing financial interests in clients is virtually a universal principle. Both the SEC and the public accounting profession have focused most of their attention regarding auditor independence on defining and enforcing prohibitions against financial

35、 interests. Elaborate rules and reporting structures have been formulated for the purpose of revealing any type of financial interest on the part of professional employees of accounting firms, their spouses, their parents, or their children. The PCAOB has adopted most of these rules, with a degree o

36、f relaxation in areas where the rules seemed unreasonable.Rotation of audit appointments. In several countries (e.g., Italy) auditors are permitted to audit a client for only a specified number of years. This type of regulation has never been seriously considered in the U.S. or the U.K., although Sa

37、rbanes-Oxley requires that individual auditors rotate off a client on a periodic basis. In France, the concept of auditor rotation is reversed: Auditors are appointed for a fixed period of time, during which time they cannot be replaced. This rule was intended to increase auditor independence, becau

38、se the auditor has less fear of being fired by the client. With regard to independence standards, the PCAOB has adopted interim rule 3600T as part of its bylaws and rules. Rule 3600T reads as follows:In connection with the preparation or issuance of any audit report, a registered public accounting f

39、irm, and its associated persons, shall comply with independence standards:(a) as described in the AICPAs Code of Professional Conduct Rule 101, and interpretations and rulings thereunder, as in existence on April 16, 2003 AICPA Professional Standards, ET sections 101 and 191 (AICPA 2002), to the extent not superseded or amended by the Board;(b) Standards