College of Business Administration ... While it will be seen that the specific regulatory structures differ among the countries investigated, .... accounting literature which have looked at the impact of organizational variables on .... as part of the state government for the purpose of regulating the public accounting profession.
REGULATING THE PUBLIC ACCOUNTING PROFESSION: AN INTERNATIONAL PERSPECTIVE
by
C. Richard Baker, Ph.D., C.P.A. Department of Accounting and Financial Management University of Essex Wivenhoe Park Colchester CO4 3SQ United Kingdom
Rick Stephan Hayes, Ph.D. Department of Accounting College of Business Administration California State University Los Angeles, California
REGULATING THE PUBLIC ACCOUNTING PROFESSION: AN INTERNATIONAL PERSPECTIVE Abstract This paper investigates the regulation of the public accounting profession in several advanced capitalist countries, including the United States, the United Kingdom and Germany. The public accounting profession has become a common feature of capitalist societies and therefore worthy of investigation. The purpose of regulating a profession in a general sense can be said to be the promotion of a consistently high level of professional practice in the public interest. A complex set of regulatory structures and practices has developed around the public accounting profession. These regulatory structures and practices attempt to define the technical and ethical duties that public accountants owe to their clients, to third parties and to the public generally. Common to members of other professions, public accountants provide services to clients. The provision of these services is sanctioned by society under the theory that the provision of the services is in the public interest. Nevetheless, the public accounting profession differs from other professions in that while public accountants provide services to clients, public accountants also assume responsibilities to shareholders, creditors and to the general public. While other professionals such as physicians and lawyers are expected to perform their services at the maximum possible level of professional competence for the specific benefit of their clients, public accountants are often expected by their clients to perform their professional services in a manner that differs from the interests of the third parties who are the implicit beneficiaries of the contractual arrangements between the public accountants and their clients. This unusual arrangement poses an ethical dilemma for public accountants. Many of the regulatory structures of the public accounting profession have developed in response to this ethical dilemma. The focus of this paper is on describing and comparing the regulatory structures of the public accounting profession in several advanced capitalist countries. While it will be seen that the specific regulatory structures differ among the countries investigated, the conflicts addressed by these regulatory structures are similar in each of the countries.
REGULATING THE PUBLIC ACCOUNTING PROFESSION: AN INTERNATIONAL PERSPECTIVE
INTRODUCTION As a profession, public accounting differs from other professions in that while public accountants receive fees for services rendered to clients (e.g. auditing; tax preparation and consultation; management consultancy; information systems design), public accountants also assume responsibilities to shareholders, creditors and to the public generally (e.g. lending credibility to financial statements).
This dual role poses an ethical dilemma for public accountants.
Regulatory structures (including laws, professional standards, educational requirements and codes of conduct) have developed in response to this ethical dilemma. These regulatory structures attempt to define the technical and ethical duties that public accountants owe to third parties, while at the same time conveying an image of high level professional conduct on the part of the public accounting profession (Parker, 1994).
The purpose of this paper is to explore some of the
regulatory structures of the public accounting profession and to investigate how these structures compare in several advanced capitalist countries.
REVIEW OF PREVIOUS LITERATURE The sociology literature views a profession as having among other attributes: a defined body of knowledge; specific recognition by society as a profession; an ethical code; and a defined cultural tradition (Abbot, 1983; Greenwood, 1957). Professions have existed for hundreds of years, but for 1
the most part, professions have developed outside of the direct control of the state. Individual persons have generally become members of professions by joining guilds or institutes which regulate the members of the profession in both the technical and the ethical sense. Violations of the written and unwritten codes of professional conduct might constitute grounds for taking disciplinary action against the offending member. Such disciplinary actions might range from warnings and reprimands to harsher penalties including expulsion from the profession. Threats of expulsion from the professional guild or institute and the corresponding loss of status and income often sufficed to cause the member of the profession to abide by the written and unwritten codes of professional conduct (Durkheim, 1933; 1957). As societies have evolved toward looser and more liberal mechanisms of social control, the regulatory structures associated with professional guilds and institutes have given way to state control and regulation (Greenwood, 1966; Abbott, 1983; Burns and Haga, 1977). At present, in most advanced capitalist countries there is a hybrid system of professional regulation composed of functions exercised both by the state and by professional institutes or associations (Parker, 1994; Bowie, 1979).
Public accountants are usually regarded as professionals because in their conduct and their practices they meet the definition of a profession in the sociological sense (Greenwood, 1966; Abbott, 1983; Burns and Haga, 1977). One commonality among professions is that the members of a profession subscribe to a code of ethical conduct which is said to be different and usually superior to that of the ethical conduct expected of ordinary persons acting in their daily lives (Parker, 1994). However, as mentioned previously, the public accounting profession differs from other professions 2
in that while public accountants receive fees for services rendered to persons and organizations whom they refer to as their clients, public accountants also assume responsibilities to third parties and to the public generally (Briloff, 1978). This unusual arrangement poses an ethical dilemma for public accountants which will be discussed further below.
Regulation of Professional Conduct Codes of conduct and other regulatory structures define the technical and ethical duties that professionals owe to their clients and to third parties and specify the sanctions that will follow as a result of failure to abide by these regulations. Although the formal regulatory structures of a profession are intended to assure the technical and ethical conduct on the part of professional practitioners, the ultimate question of how the profession functions in society rests upon the actual conduct of its practitioners.
From a general philosophical perspective, ethical conduct may be viewed from two perspectives: the deontological and the teleological. The deontological or act-oriented approach holds that there are certain axioms of right conduct that dictate the actions that a person should take regardless of the situation (Frankena, 1963). Pursuant to the deontological approach, actions are seen as intrinsically right or wrong. Opposed to the deontological approach is the teleological or results-oriented approach which holds that the rightness or wrongness of an act is determined by its consequences. The teleological approach is sometimes referred to as consequentialism (Frankena, 1963). The study of ethical conduct may also be approached from a perspective which takes into 3
consideration both the deontological and teleological aspects of actions. In other words, in their actual lives, persons evaluate the inherent rightness or wrongness of their acts and/or those of others, and simultaneously, they evaluate the consequences of their acts and/or those of others. Thus, a blend of deontological and teleological factors affects the conduct of persons acting in their daily lives. Furthermore, organizational and cultural factors have an impact on conduct, regardless of the deontological or teleological views held by the actors. This means that the organizational settings in which the actors find themselves are often determinative of their conduct regardless of their beliefs and attitudes towards the ultimate rightness or wrongness of their acts (Hunt & Vitell, 1986; Ajzen & Fishbein, 1973; Frankena, 1963). There have been a number of studies in the accounting literature which have looked at the impact of organizational variables on conduct (see for example Schilit, 1984; Loeb, 1972; Loeb, 1971).
Another way of looking at ethical conduct is from a psychological perspective. The "moral development paradigm" is a well established model in the field of psychology (Kohlberg, 1981). The moral development paradigm focuses on an individual’s beliefs and attitudes and how the individual’s belief system controls conflict resolution and ethical problem solving in actual life. Kohlberg’s studies of beliefs in relationship to conduct were founded on a psychological model derived from Piaget. According to Piaget (1932) a person’s ethical belief system develops through a series of stages over time as a result of social interactions. Kohlberg (1958) elaborated upon the stages of ethical development as postulated by Piaget in order to explain the processes that appear to cause a particular individual to act according to a certain set of principles. Kohlberg put forth a 4
model of ethical development consisting of a series of cognitive steps. According to this model a person’s ethical judgment develops in stages. At any given point in time, a person is at particular stage of ethical judgment and then proceeds to the next stage depending upon the person’s belief system. In the accounting literature, Ponemon (1990) and others have employed the Kohlberg model in several empirical studies (see Ponemon & Gabhart, 1990; Arnold & Ponemon, 1987) with the interesting result that individuals at higher level positions in public accounting firms do not necessarily demonstrate higher levels of ethical and moral development as measured by the Defining Issues Test (Ponemon, 1990; Rest, 1979).
Sociological studies of professional conduct are often embroiled in the definition and meaning of professionalism (Abbott, 1983; Freedman, 1978; Greenwood, 1966; Burns & Haga, 1977). In the accounting literature, there have been a number of studies which have approached the ethical conduct of public accountants from a sociological perspective, particularly in regard to independence from clients (see for example Baker, 1993; Gaa & Smith, 1985; Knapp, 1985; Lightner et al., 1982; Aranya et al., 1981; Baker; 1977). These studies recognize the ethical dilemmas faced by public accountants and discuss how organizational structure variables act to ameliorate or exacerbate these dilemmas.
Some recent studies have taken a more critical look at ethical issues in the public accounting profession. Parker (1994) asserts that the organized public accounting profession has frequently issued statements emphasizing its status as a profession and its role in serving the public 5
interest. These attempts to influence the public perception of the public accounting profession may reflect a desire to enhance the economic and social self-interests of the profession (Armstrong, 1985). While the professional standards of the public accounting profession have usually been expressed in terms of advancing the public interest, it can be seen that these standards are also inextricably linked with the profession’s private interests (Willmott, 1986). In a study of ethical pronouncements issued by the Australian public accounting profession, Parker (1987) identified protection of the profession as a primary rationale underlying many of the ethical pronouncements. Parker (1994) also found that the majority of disciplinary actions taken by the professional accounting institutes in Australian during the period 1961 to 1987 were oriented towards the private interests of the profession rather than the public interest.
Parker’s findings in Australia tend to support some earlier findings of Briloff (1978) and Montagna (1974) concerning the public accounting profession in the United States to the effect that regulatory structures in the United States have tended to focus on disciplining acts such as: violation of prohibitions against advertising; driving while intoxicated; filing false tax returns; or embezzlement of funds; all of which, while important and deserving of disciplinary action, tend not to address the central issue of the conflict of interest inherent in the public accountant’s role which arises from the need to serve the client’s interests while simultaneously protecting the public interest.
6
The following sections will discuss the regulatory structures of the public accounting profession in the United States, in the United Kingdom and in Germany. While it will be seen that the regulatory structures differ among the three countries investigated, the problems addressed by these structures are similar in each of the countries. REGULATING THE PUBLIC ACCOUNTING PROFESSION The United States In the United States the public accounting profession is regulated along state lines. In order to become a Certified Public Accountant (CPA) an individual must meet the requirements established by the laws of a particular state. The laws of the states are similar in that each state requires a certain minimum level of education and passage of the Uniform CPA Examination, which is prepared and graded by the American Institute of CPAs (AICPA). In addition to the educational pre-requisites and passage of the Uniform CPA Examination, most states also require a certain minimum period of practice experience under the supervision of a licensed CPA. This period of experience ranges from zero to two years depending on the state. Once an individual has been granted a license as a CPA, as long as the license is maintained, the person is deemed fully qualified to practice as a CPA. Each state also has a board of accountancy (or other similar agency) as part of the state government for the purpose of regulating the public accounting profession. Most of the state boards of accountancy have adopted codes of professional conduct to which a licensed public accountant must adhere under penalty of being disciplined or having the license revoked.
7
A second form of regulation of the public accounting profession in the United States is embodied in the AICPA, a nationwide, voluntary association of CPAs. As mentioned previously, the AICPA is the preparer and grader of the Uniform CPA Examination, therefore, the AICPA plays an important role in determining the minimum level of technical competence that CPAs must possess. In addition, the AICPA has established a Code of Professional Conduct which members of the AICPA must observe upon penalty of suspension or expulsion from the AICPA. Although expulsion from the AICPA would entail a certain degree of opprobrium, it would not prevent a CPA from practicing. Only revocation of the license to practice by the state which granted the license would cause forfeiture of the right to practice as a CPA. In most of the states there are also state societies of CPAs in which membership is voluntary. Many of the state CPA societies are associated closely with the state boards of accountancy and may in fact control such boards. The regulatory structures of the state boards of accountancy and those of the state CPA societies thus may be parallel or even merge in some instances. The AICPA also coordinates with the state boards of accountancy and the state societies of CPAs in regulating CPAs.
In addition to the regulation of the public accounting profession by the state boards of accountancy and the AICPA, the Securities and Exchange Commission (SEC) regulates certain aspects of the public accounting profession in the United States. The SEC is an agency of the US federal government that was created by the Securities Exchange Act of 1934 (the 1934 Act. The function of the SEC is to regulate the public issuance and trading of securities. The 1934 Act requires companies with publicly traded securities to file annual audited financial statements with 8
the SEC and to issue such statements to their shareholders and bondholders. The audit must be performed by a CPA. Under its rules of practice, the SEC may discipline an individual CPA practitioners or a firm of CPAs if the auditor does not abide by established rules of professional conduct.
Included among the penalties that may be imposed by the SEC are temporary or
permanent suspension of practice before the SEC as well as civil and criminal penalties such as fines or imprisonment. It is rare for criminal penalties to be imposed. Suspension of practice, either for a temporary period or permanently, is more common (Graese, 1980).
Various regulatory structures have been implemented jointly or in parallel with the SEC, the AICPA and the various state boards of accountancy. These regulatory practices include the establishment of mandatory requirements for continuing professional education, peer review of working paper documents, second partner reviews, staff training and various other quality control standards that must be maintained by firms which audit public companies. In order to implement these regulatory structures, the AICPA has created a Division for Firms within the AICPA. In the past, it was possible to become a member of the AICPA only as an individual CPA. Currently, CPA firms may become members of the Division for Firms of the AICPA. The Division for Firms, in turn, is divided into the SEC Practice Section and the Private Companies Practice Section.
The Public Oversight Board (POB) of the SEC Practice Section was created by the AICPA to add another level of regulation within the overall regulatory structure of the public accounting profession. The POB was intended to be an independent, private sector body that monitors and 9
reports on the regulatory procedures of the SEC Practice Section of the Division for CPA Firms of the AICPA. Effectively, only firms that are members of the SEC Practice Section of the Division of Firms of the AICPA are allowed to audit public companies in the United States.
As a
consequence the regulatory procedures of the SEC Practice Section and the POB have come to play an important role with respect to the regulation of public accounting as it relates to audits of financial statements of public companies (POB, 1994).
The SEC Practice Section is composed primarily of large public accounting firms (i.e. the ‘Big 6’) since these firms audit the vast majority of public companies in the US. The large public accounting firms are multinational business enterprises with operations that transcend the boundaries of state governments in the US as well as international boundaries. It is unclear whether the regulatory structures of state and federal governments and the AICPA, which were designed to regulate practice units comprised of relatively small groups of CPA practitioners, are capable of functioning effectively in a multinational environment. In the US, the SEC has generally had the power to regulate large practice units that come under its jurisdiction. However, the SEC may not have sufficient funding and technical resources to address the problems posed by an increasingly multinational environment. The large public accounting firms are under financial and competitive pressures causing them to emphasize the non-audit aspects of their professional practices (Robson et al., 1994; Baker, 1993). The increasingly multinational aspect of public accounting practice and the dominance of this practice by the large public accounting firms raise the question of whether the
10
regulatory structures of the past, which developed in an era of small practice units, are sufficient to provide adequate regulation of the public accounting profession in the future (POB, 1994).
In 1994, the POB issued a report prepared by the Advisory Panel on Auditor Independence. The Advisory Panel Report urged the accounting profession to look to the board of directors of a company as the client of the auditor and not to corporate management. The report called for a direct interface between the entire board of directors and the auditor at least annually and an expanded interface with the audit committee of the board. In addition the report stated that in order to increase the value of the audit there should be a new level of candor from the auditor. Auditors should not only apprise the board of directors of a company of what is acceptable accounting, they should also be expected to express their views, as accounting experts, on the appropriateness of the accounting principles used or proposed by the company, the clarity of the financial disclosures, and the degree of aggressiveness or conservatism of the accounting principles and underlying estimates reflected in the company’s financial statements (POB, 1994). In many respects the Advisory Panel Report goes directly to the heart of the ethical dilemma of the public accounting profession. It remains to be seen if there will be any changes made in the regulatory structures of the public accounting profession as a result of this report.
The next section will discuss the regulatory structure of the public accounting profession in the United Kingdom.
11
The United Kingdom In contrast to the US, the public accounting profession in the United Kingdom (UK) is regulated primarily by professional institutes and to a lesser extent by state regulatory authorities. There are six professional institutes of accountants which are recognized in the United Kingdom and in Ireland1. These institutes establish the educational pre-requisites, examination standards and professional experience requirements necessary for membership in the respective institutes. Although the institutes have been granted formal recognition via the Companies Acts, there are reasonably few specific governmental requirements imposed by law on the public accounting profession.
Hence the institutes are quite powerful in establishing the technical and ethical
standards of the public accounting profession which must be followed on pain of disciplinary sanction or expulsion from an institute. The regulatory structures of the institutes therefore are relatively more important than they are in the United States (ICAEW, 1986). In addition, control of individual behavior through societal expectations may be more effective in the UK than in the US, and therefore the regulatory structures of the UK professional institutes may be more effective in controlling deviant behavior. Nevertheless, the movement towards an increasing level of multinational practice among the large public accounting firms has affected the British practices of the large public accounting firms in a manner similar to that of the United States.
1
The six institutes are: the Institute of Chartered Accountants in England and Wales (ICAEW); the Institute of Chartered Accountants in Scotland (ICAS); the Institute of Chartered Accountants in Ireland (ICAI); the Chartered Association of Certified Accountants (CACA); the Chartered Institute of Management Accountants (CIMA); and the Chartered Institute of Public Finance Accountants (CIPFA).
12
Robson et al. (1994) have discussed the problems associated with the issuance of the Eighth European Community Company Law Directive in 1986. They indicate that the large public accounting firms have a desire to expand their practices beyond the traditional focus on audit and tax services into a broader scope of services that fall under the rubric of "financial services" and that the issuance of the Eighth EC Directive has provided an opportunity to assure that European company law would not prevent public accountants in the UK from providing a range of non-audit services. Robson et al. (1994) discuss the debates surrounding the question of whether the large public accounting firms should expand their scope of services while at the same time maintaining their public interest focus. The conservative governments in Britain during the 1980s and 1990s have generally adopted an attitude toward the financial services industry which emphasizes the concept of self-regulation. This perspective has been extended to the public accounting profession, reinforcing the general impression that the public accounting profession in the UK has been allowed a greater degree of self-regulation than in the US. After the issuance of various position papers by the professional institutes, the UK government granted the public accounting profession the status of a Recognized Professional Body (RPB) and thereby exempted the accounting profession from certain forms of government regulation under the Financial Services Act of 1986. In an action related to the efforts to secure RPB status, the governing body of the Institute of Chartered Accountants of England and Wales (ICAEW) issued the Worsley Report which has been criticized by Robson et al. (1994) as follows: "...an illuminating example of the way professional ideology is invoked and reformed in order to legitimate the professional order to its members. The concept of the ’public interest’, commonly and centrally associated with the professional ideology is recast by the 13
Worsley report, in terms of the individual member’s private interest in pursuing new and expanding markets for accounting labour..." (p. 550).
Thus it can be seen that the regulatory structures of the public accounting profession in the UK, which are controlled by the professional institutes, may less than effective in an environment characterized by the desire on the part of the large public accounting firms to expand their scope of services into areas not directly related to primary function of enhancing the credibility of financial statements.
The next section will discuss the regulatory structure of the public accounting profession in Germany.
Germany In Germany, public accountants are designated as Wirtschaftsprufers (WPs). The public accounting profession is strictly controlled by law and by regulation. It is difficult to become a WP in Germany. Most individuals are not admitted to fully licensed practice until they are above the age of thirty and after a number of years of supervised practice. As a consequence it might be expected that the level of technical skill and ethical conduct among public accounting professionals in Germany would be high. On the other hand, the role of WPs in the German economy is different from that of public accountants in the United States and in the United Kingdom.
German
companies have traditionally obtained capital directly from banks, and banks typically have had equity interests in major German corporations which have entitled them to representation on the 14
board of directors as well as the ability to obtain non-public information in order to assess the position of their debt and equity interests. Consequently, the emphasis on the ‘true and fair view’ of financial reporting has not played as an important role in German public accounting as it has in the UK. Therefore, the ethical dilemma between the public interest role of public accountants and the enhancement of their private interests does not arise as frequently in the German public accounting profession as it does in the US and in the UK.
The Wirtschaftspruferkammer (WPK) to is the primary regulator of the public accounting profession in Germany (Quick, 1994). The WPK is a quasi-judicial body that functions under German law rather than under the auspices of the public accounting profession. In addition, WPs function for the most part pursuant to German law. The WPK can take various types of action with respect to disciplining WPs. These actions range from issuing what is referred to as an ‘instruction’ through warnings and reprimands and ultimately to expulsion from the profession. If a violation is sufficiently grave that the issuance of a reprimand seems to be insufficient, the WPK can request disciplinary proceedings by a court of law. Disciplinary measures that a court can impose include: a warning; a reprimand; a fine; and exclusion from the profession (Quick, 1994).
In order to take a disciplinary action against a WP it must be determined that the WP has culpably (i.e. intentionally or negligently) violated professional duties. Quick indicates that it is usually a behavior which damages the reputation of the profession (even when it happens outside the conduct of the profession, such as driving under the influence of alcohol). Such behaviors are 15
punished more severely than misconduct in auditing financial statements (Quick, 1994). Exclusion from the profession is rare. The issuance of a reprimand by the WPK as well as a disciplinary action generally consists of a declaration which expresses the expectation that the WP will not violate his or her duties in the future (Quick, 1994).
In a study of disciplinary actions against public accountants in Germany, Quick (1994) found that over a period from 1961 to 1992 the number of disciplinary proceedings did not increase despite an increase in the number of WPs. There also appeared to be a trend toward more lenient punishments. The nature of the violations also changed (especially with regard to an increase in the number of violations against the prohibition of advertising).
A direct link between certain
violations and certain disciplinary measures was found only with regard to exclusion from the profession (e.g. violation of certain criminal laws such as fraud, culpable and serious collapse of the economic condition of the WP). The reason for this appeared to be that besides the gravity of the violation, other criteria were considered in fixing the penalty (e.g. the extent of the culpability, the number of violations, the personal situation of the WP). Quick and other German commentators have criticized the status of the regulatory structures in Germany for several reasons. One criticism is that the regulation of the professional conduct by the WPK is a formal control without great substance. Another criticism is that a small proportion of all proceedings of the disciplinary actions result from systematic and regular collection of information. Most disciplinary actions were stimulated from outside the public accounting profession and were deemed to be random in nature.
16
Furthermore, the influence of WPs on the regulatory structures and the limited opportunities for the WPK to collect information and to investigate were also criticized (Quick, 1994).
SUMMARY AND CONCLUSION In this investigation of the regulation of the public accounting profession in the US, the UK and Germany it can be seen that while the specific regulatory structures differ among the countries, the problems addressed by the structures are similar in each of the countries. The public accounting profession has developed over a period of time into an integral component of advanced capitalist societies. Common to members of other professions, public accountants provide services to clients. The provision of these services is sanctioned by society because it is felt that the services are in the public interest. Nevertheless, public accountants differ from other professionals in that while they receive fees for services rendered to persons and entities referred to as clients, public accountants also assume responsibilities to third parties and to the public generally. While other professionals such as physicians and lawyers are expected to perform their services at the maximum possible level of professional competence for the benefit of their clients, public accountants may at times be expected by their clients to perform their professional services in a manner that differs from the interests of third parties who are the beneficiaries of the contractual arrangements between the public accountants and their clients. This unusual arrangement poses an ethical dilemma for public accountants. Regulatory structures in the public accounting profession (including laws, professional standards, educational requirements and codes of ethics) have developed in order to define the ethical duties that public accountants owe to third parties and to provide assurance of an 17
adequate level of ethical conduct on the part of public accounting professionals. The purpose of this paper has been to explore some of the regulatory structures in the public accounting profession and to investigate how these structures compare among the US and other countries. We find that the conflicts inherent in the public accountant’s role are continuing despite the existence of increasingly complex regulatory structures. The financial and competitive pressures experienced by the large, multinational public accounting firms is leading them to seek revenues through expansion of their scope of services into many areas. The size and scope of the multinational practices of these firms raises the question of whether the regulatory structures of state and national governments and professional institutes are any longer sufficient to effectively regulate a multinational practice that transcends all former boundaries.
18
REFERENCES Abbott, A., "Professional Ethics," American Journal of Sociology (1983) Vol. 88, pp. 855-885.
Ajzen, I. & Fishbein, M., "Attitudinal and Normative Variables as Predictors of Specific Behaviors," Journal of Personality and Social Psychology (1973) Vol. 27, pp. 41-57.
American Institute of Certified Public Accountants, Professional Standards, Volume 2 (New York: AICPA, 1993).
Armstrong, P., "Changing Management Control Strategies: The Role of Competition Between Accountancy and Other Organisational Professions," Accounting, Organizations and Society (1985) pp. 129-148.
Aranya, N., Pollock, J. & Amernic, J., "An Examination of Professional Commitment in Public Accounting," Accounting, Organizations and Society (1981) pp. 271-280.
Arnold, D. & Ponemon, L., "Moral Judgment Prospective for the Various Auditing Judgment Issues," Proceedings of the British Accounting Associations’s Annual Meeting, Glasgow University (15 April 1987).
19
Baker, C.R., "Self-Regulation in the Public Accounting Profession: The Response of the Large, International Public Accounting Firms to a Changing Environment," Accounting, Auditing, Accountability Journal (1993) Vol. 6, No. 2, pp. 68-80.
Baker, C.R., "Management Strategy in a Large Accounting Firm," The Accounting Review (July 1977) Vol. 52, No. 3, pp. 576-586.
Baker, C.R., "An Investigation of Differences in Values: Accounting Majors vs. Non-Accounting Majors," The Accounting Review (October 1976) Vol. 51, No. 4, pp. 886-893.
Barber, B., "Some Problems in the Sociology of the Professions," in Lynn, K. (ed.), The Professions in America (Beacon Press, 1965).
Bowie, N., "Business Codes of Ethics: Window Dressing or Legitimate Alternative to Government Regulation?" in Beauchampt, T. & Bowie, N. (eds.), Ethical Theory and Business (Englewood Cliffs, NJ: Prentice-Hall, 1979).
Briloff, A., "Codes of Conduct: Their Sound and Their Fury," in De George, R. & Picher, J. (eds.) Ethics, Free Enterprise and Public Policy: Original Essays on Moral Issues in Business (London: Oxford University Press, 1978).
20
Burns, D. & Haga, W., "Much Ado About Professionalism: A Second Look at Accounting," The Accounting Review (July 1977), pp. 705-715.
Carey, J., The Ethical Standards of the Accounting Profession (New York: AICPA, 1966).
Cooper, D., Hayes, D. & Wolf, F., "Accounting in Organized Anarchies: Understanding and Designing Accounting Systems in Ambiguous Situations," Accounting, Organizations and Society (1981) Vol. 6, pp. 119-132.
Davidson, A., "Archeology, Genealogy, Ethics," in Hoy, D., Foucault: A Critical Reader (New York: Basil Blackwell, 1986).
Dreyfus, H. & Rabinow, P., Michel Foucault (Brighton: The Harvester Press, 1982).
Durkheim, E., The Division of Labor in Society, translated by Simpson, G. (Free Press, 1933).
Durkheim, E., Professional Ethics and Civic Morals, translated by Brookfield, C. (New York: Routledge and Kegan Paul, 1957).
Frankena, W., Ethics (Englewood Cliffs, NJ: Prentice-Hall, 1963).
21
Freedman, B., "A Meta-Ethics for Professional Morality," Ethics (1978) pp. 1-19.
Gaa, J. & Smith, C., "Auditors and Deceptive Financial Statements: Assigning Responsibility and Blame," Contemporary Accounting Research (1985) pp. 219-241.
Graese, C., "Honesty and Professional Ethics: Focus on Accounting," in Hill, I. (ed.) The Ethical Basis of Economic Freedom (New York: Praeger, 1980).
Greenwood, E., "The Elements of Professionalization," in Vollmer, H. & Mills, D. (eds.) Professionalization (Englewood Cliffs, NJ: Prentice-Hall, 1966).
Hunt, S. & Vitell, S., "A General Theory of Marketing Ethics," Journal of Macromarketing (1986), pp. 5-16.
Knapp, M., "Audit Conflict: An Empirical Study of the Perceived Ability of Auditors to Resist Management Pressure," The Accounting Review (April 1985) pp. 202-211.
Kohlberg, L., The Development of Modes of Moral Thinking and Choice in the Years Ten to Sixteen, unpublished Ph.D. Dissertation, (University of Chicago, 1958).
22
Kohlberg, L., The Meaning and Measurement of Moral Development (Worcester, MA: Clark University Press, 1981).
Lehman, C. & Tinker, T., "The Real Cultural Significance of Accounts," Accounting, Organizations and Society (1987) Vol. 12, pp. 503-522.
Lightner, S., Adams, S. & Lightner, K., "The Influence of Situational, Ethical, and Expectancy Theory Variables on Accountants’ Underreporting Behavior," Auditing: A Journal of Practice and Theory (1982) pp. 1-12.
Loeb, S. Ethics in the Accounting Profession (New York: John Wiley & Sons, 1978).
Loeb, S., "Enforcement of the Code of Ethics: A Survey," The Accounting Review (January 1972) pp. 1-10.
Loeb, S., "A Survey of Ethical Behavior in the Accounting Profession," Journal of Accounting Research (Autumn 1971), pp. 287-306.
Montagna, P., "The Public Accounting Profession: Organization, Ideology and Social Power," in Freidson, E. (ed.) The Professions and Their Prospects (Beverly Hills: Sage, 1973).
23
Montagna, P., Certified Public Accounting: A Sociological View of a Profession in Change (Houston: Scholars Books Co., 1974).
Parker, L., "Professional Accounting Body Ethics: In Search of the Private Interest," Accounting, Organizations and Society (1994) pp. 507-525.
Parker, L., "An Historical Analysis of Ethical Pronouncements and Debate in the Australian Accounting Profession," Abacus (1987), pp. 126-140.
Ponemon, L., "Ethical Judgments in Accounting: A Cognitive-Development Perspective," Critical Perspectives on Accounting (1990) Vol. 1, No. 2, pp. 191-215.
Ponemon, L. & Gabhart, D., "Auditor Independence Judgments: A Cognitive-Developmental Model and Experimental Evidence," Contemporary Accounting Research (1990).
Public Oversight Board, Strengthening the Professionalism of the Independent Auditor: Report to the Public Oversight Board of the SEC Practice Section, AICPA, From the Advisory Panel on Auditor Independence (Stamford, CT: Public Oversight Board, 16 September 1994).
24
Puxty, A., Willmott, H., Cooper, D. & Lowe, T., "Modes of Regulation in Advanced Capitalism: Locating Accountancy in Four Countries, Accounting, Organizations and Society (1987) Vol. 12, pp. 273-291.
Rest, J., Development in Judging Moral Issues (Minneapolis, MN: University of Minnesota Press, 1979).
Robson, K., Willmott, H., Cooper, D. & Puxty, T., "The Ideology of Professional Regulation and the Markets for Accounting Labour: Three Episodes in the Recent History of the U.K. Accountancy Profession," Accounting, Organizations and Society (1994) pp. 527-553.
Schilit, H., "Deviant Behavior and Misconduct of Professionals," The Woman CPA (April 1984) pp. 20-24.
Quick, R., "Disciplinary Actions Against Auditors in Germany," Presented at the Fourth Maastricht Auditing Research Symposium, University of Limburg (Maastricht, The Netherlands, 25 October 1994).
Willmott, H., "Organising the Profession: A Theoretical and Historical Examination of the Development of the Major Accountancy Bodies in the UK," Accounting, Organizations and Society (1986) pp. 555-580. 25
