PwC Hit with $625 Million in Damages for Negligence in Bank-Fraud Case Brought by the FDIC

When it gets too complicated for senior auditors, send in a “college-aged intern.”

[This version corrects a mix-up between PwC and KPMG in the bottom two paragraphs of the prior version].

For PricewaterhouseCoopers, having for years rubber-stamped as outside auditor the financial statements of Colonial Bank in Alabama is getting expensive.

Colonial, the 25th largest bank in the US at the time, collapsed unceremoniously in 2009, brought down in part by a $2.3 billion fraud scheme it had going on with its biggest customer, Taylor Bean & Whitaker Mortgage, the 12th largest mortgage lender in the US, which had collapsed shortly before the bank.

The FDIC, which took over Colonial and made its insured depositors whole, was not amused. In November 2012, it sued PwC as the outside auditor of Colonial, accusing it of negligently auditing the bank from 2003 to 2005 and in 2008.

Today, federal district judge Barbara Jacobs Rothstein ruled that PwC, which in December was found negligent in detecting the fraud scheme at the bank, must pay the FDIC $625.3 million in damages, the full amount the FDIC had requested – and one of the largest awards for accounting malpractice.

Others involved in the scheme:

  • In February, Deloitte & Touche, which had been Taylor Bean’s outside auditor, had settled allegations by the Justice Department for $149.5 million.
  • In April, Crowe Horwath, which had been Colonial’s internal auditor, had settled allegations by the FDIC for $60 million.
  • In 2016, PwC had settled with Taylor Bean’s bankruptcy trustee, but terms were not disclosed.
  • Taylor Bean’s former Chairman Lee Farkas is serving a 30-year stint in the hoosegow after his 2011 conviction on 14 fraud and conspiracy charges.
  • Several other people, including employees of Colonial, pleaded guilty or were convicted for their roles in the scheme.

Today’s ruling was about the amount of the award. In December, Judge Rothstein had already ruled that PwC had negligently failed to design and perform the audits, based on PwC’s own admissions, to detect the $2.3-billion fraud scheme between Colonial and Taylor Bean. It was the first time that a federal district judge ruled that an audit firm was liable for failing to detect a fraud under the Sarbanes-Oxley act.

In the December ruling, Judge Rothstein had found, according to Reuters:

The auditor relied on the chief architect of the fraud, Taylor Bean chair Lee Farkas, to verify key information about the collateral underlying a Colonial credit facility for Taylor Bean. PwC also signed off on Colonial’s audit without ever understanding the third and most complex iteration of the fraud, which involved a credit facility based on phantom mortgage securitizations.

After an auditor who was supposed to make sense of the transactions gave up, saying they were “above his pay grade,” PwC assigned a college-aged intern to evaluate the nearly $600 million asset.

Judge Rothstein was distinctly harsh about PwC’s failings. Basing Colonial’s certification on Farkas’ account of Taylor Bean’s collateral was “quintessentially the same as asking the fox to report on the condition of the hen house,” she wrote. And charging an intern to decipher a loan facility beyond the expertise of a senior auditor was a “truly astonishing” departure from PwC’s mandate, the judge wrote.

And there’s more…

Taylor Bean was one of Colonial’s most important customers, Judge Rothstein said, and the bank was at first eager to help the mortgage lender survive overdrafts. Later, as the fraud ballooned, Colonial execs frantically tried to recoup Colonial’s money from Taylor Bean. According to the judge’s decision, over the course of several years, to keep the scheme secret, Colonial execs lied to PwC auditors, circumvented internal controls by “recycling” mortgage data and even created wire transfers to trick PwC into believing Taylor Bean collateral mortgages had been paid off.

Today’s ruling awards the FDIC the full damages it had sought. PwC had earlier asked the judge to keep the damage award down to $306.7 million. Today, PwC said that it intends “to pursue an appeal of this matter at the earliest opportunity.”

And the bitter irony?

PwC is one of the Big Four audit firms. They include KPMG, which confidence-inspiringly and diligently performs the annual audits of the financial statements of each of the 12 regional Federal Reserve Banks – such as the New York Fed and the San Francisco Fed – along with the combined financial statements of the Federal Reserve System. So when things get complex – and there surely are very complex and immense transactions at the Fed – and senior auditors can’t figure out what they’re looking at and can’t make heads or tails of it, they’re sending in a “college-aged intern” to paper over it?

KPMG is also the firm that audited the financial statements of construction and outsourcing giant Carillion, which collapsed in January. It’s  part of the audit oligarchy that is now down to just four mega-firms, and they audit nearly all of the S&P 500 companies while also providing a host of consulting and tax services.

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  63 comments for “PwC Hit with $625 Million in Damages for Negligence in Bank-Fraud Case Brought by the FDIC

  1. Gershon says:

    I am Jack’s total lack of surprise.

  2. Armando Rubio says:

    As an auditor of much smaller entities, I can assure you that often times auditors especially those who are not forensic auditors simply don’t perform adequate due diligence to save time. Also if fraud is not immediately detectable it will likely not be found, heck it might even be done by an intern…

    • van_down_by_river says:

      I don’t envy your occupation, I would not want to unravel the mess that has become modern day accounting.

      I thought the blurb for the article was incorrect in stating PwC audits the Fed, I was fairly certain that was KPMG, but I see he was referring to the regional branches.

      In any case, who really believes there is a true audit of the Fed? The Fed controls the world’s reserve currency and they were incorporated within our borders and have comingled within our government – it is the duty of our government to thoroughly investigate this company to be certain nothing untoward is happening. But far from this, it is an institution that appears to do what it wants when it wants and if anyone questions them they are met with the reply “hey don’t bother us we’re busy saving the world”.

      You guys may want to park your wealth in their dollar scheme but I’m not having anything to do with their product, beyond what I need to purchase food. Ten years ago they shifted their official primary mandate from preservation of the value of the dollar to debasement of the dollar – not making that up – their primary mandate is to debase the value of their own product. With or without an audit why would you want to own their product.

      Also, I was amazed to see that a banker was sent to prison for committing fraud. Fourteenth largest bank must have been far enough down the food chain to be vulnerable – after all, what retiring Fed head is going to want a figure head position at the 14th largest (and now defunct) bank. The poor guy was stripped of his power and influence over those who regulated him. Bet he was a deer in the headlights.

      • Wolf Richter says:

        Concerning KPMG and the Fed, you’re correct, as I myself said just a couple of weeks ago, and as I totally mixed it up now. Grrrr

      • Dan Romig says:

        The McFadden Act passed by Congress on February 25, 1927 states that it is not ” … the duty of our government to thoroughly investigate this company (the Fed) to be certain nothing untoward is happening.” And that’s a damn shame as history shows that would have been the preferential wording of this incredibly important law.

        Please read the Sec. 18 and Sec. 19 on page 11. It gives Congress and the Federal Reserve Board the power to oversee the Fed; but they have no mandate to do so, nor do they share that power of oversight with any other entity.

        Van, you are so right about bankers being sent to prison.

      • Armando Rubio says:

        You’d be surprised what a mess even small municipal entities are.

      • Robert says:

        “Ten years ago they shifted their official primary mandate from preservation of the value of the dollar to debasement of the dollar – not making that up.”
        I hate to inform you that from the very beginning, the Fed was all about debasing- or providing for the debasement- of the currency. Read: “Official title: An Act To provide for the establishment of Federal reserve banks, to furnish an elastic currency…”
        Andrew Jackson’s writings, while a little archaic, are perfectly clear as to the abuses and self-dealing by the bankers owning the Central Bank, and every one of his warnings has come true.
        There is no reason why any nation determined to live within its means, has need for anything but a normally functioning Treasury Department- and no “central bank” (the very term was such a dirty word that it was avoided in the press until Nixon shamefully declared “We’re all Keynesians now” and “closed the gold window,” meaning severed the dollar from any anchor it had.
        Worth considering on this, the Fourth of July what tyrants we were fighting against.

      • Caliban says:

        The Laws of Physics are immutable and one of those laws is Thermodynamics. Essentially, the laws of thermodynamics states that the energy cost of extracting energy from underground will rise to the point at which the net energy provided is zero. At that point, or likely long before it, all fiat currencies, which are essentially just proxies for energy, will become worthless. I won’t make predictions for the date because, as you know, making predictions is hard, especially about the future. We are either approaching, are at it already or maybe even on the downslope of Seneca’s Cliff of Collapse. Expect many more such “Ponzi-like” collapses in the coming years.

  3. Old dog says:

    None of the executives of the consulting firms who were supposed to audit the companies involved in the 2008 financial debacle lost their pay and bonuses. I doubt PwC’s CEO will lose his.

    Equifax CEO Richard Smith stepped down amid a hacking scandal which affected 143 million people. But not before cashing in $15M in compensation and a $18M pension. Equifax executives sold an unusual amount of stock before the breach was publicly disclosed.

    Who audits the auditors? The SEC? A part-time banjo player? A 12-year-old kid after he gets out of school?

    • van_down_by_river says:

      Who watches the watchmen? As it turns out, nobody. The adults all left the building along time ago. Now we are left with a bunch of grown children fighting over the spoils like hyenas around a carcass. Those of us too weak to challenge the hyenas watch from a safe distance, slowly starving.

  4. Bobber says:

    This is what happens when your average Big 4 partner is trying to bring home a salary around $1M per year. To make that kind of money, you have to increase profitability. You cut costs by hiring lots of college kids that know nothing. You put your best people in practice development and apply the “bait and switch”.

    I worked in the Big 4 for many years and know how the sausage is made. The incentive systems in these firms do not reward the person who wants to do a quality job. They reward the rain makers.

    • kiers says:

      so a $625Mn fine payable by PWC to the SEC must be coming out of the Partner’s coffers directly and not the firms?

    • Armando Rubio says:

      I believe the go-to excuse is that they performed the audit according to GAAP if they didn’t find anything it the lawmaker’s fault.

    • RagnarD says:

      To clarify for those who don’t know the lingo….
      Rainmaker : those who close the deal with the big client.

      Which is Often, Pretty much the opposite, personality wise, of a dogged, fact checking accountant.

  5. raxadian says:

    The thing is, the Equifax hack happened because they slashed the tech support budget. Any competent tech guy would have installed that update.

    An easy way to see if a company is having fraudulent activities is just look at how much debt it has been taking in recent years. It does not matter if they supposedly paid that debt, taking too much debt is still suspicious.

    Of course that’s not a catch all, but it helps.

    Then again Leveraged Buy Outs are Legal aren’t they?

    • gina says:

      thats one of bill blacks 4 steps to control fraud

    • Enquiring Mind says:

      One handy rule: Would you want to interact with a company that under-invested in IT?

      Variation: Would you want to work for a company that did not invest in ongoing IT training for its staff?

      Either one could lead to some control fraud, or maybe just to failure due to false economies and incompetence.

  6. MCH says:

    Wonder how much the intern got paid. Was he sanctioned? Where is this intern working now?

  7. raxadian says:

    Oh and here is yet another legal scam to US taxpayers:

    To give an example:

    Apple got $321m in subsidies for a North Carolina data center.

    Jobs created? 50

    Cost per job? $6.4m

    With those guys taxes they will get the money back in just a few centuries… what do you mean humans rarely live more than a hundred years?

    • MCH says:

      Sorry about getting off point, but Apple has lost its way. It went from a CEO yammering about innovation and sometimes delivering to just a CEO yammering about innovation like talking points and never delivering.

      That’s right, Apple fans, meet your Steve Ballmer, only thinner, wears glasses, and seems to be more of a robot, oh, and lest I forget, makes more money than Steve Ballmer ever did.

      But hey, you did forget the construction jobs that Apple data center temporarily brought to NC. That should count for something.

      • Kent says:

        BS. After billions in R&D Apple came out with a microcomputer you can where on your wrist! And it has a very cool app that will tell you what time it is!

        /sarc for those on the spectrum…

        • MCH says:

          Also, don’t forget the courage it took to remove the earphone jack. That was a brilliant piece of innovation defended by rabid fans everywhere while Apple padded their bank accounts further with wireless earbuds.

  8. Todd H. says:

    The management of money and banking should be the responsibility of Congress and the Treasury Department. “The Fed” is an abortion of this obligation to a consortium of private bankers.

    Furthermore, most of the Fed governors are trained in a pseudo-science (neoclassical economics) that is a close cousin to astrology and has zero application to the real world of banking. The Fed has proven itself incapable of managing the banking system competently, so it is no surprise that they would hire PwC to rubber stamp its books.

    • Wolf Richter says:


      In Argentina, the management of money is taken care of by a department of the Ministry of Finance, which is called the Central Bank of Argentina (BCRA), but just does the bidding of politicians in power, and therefore has reduced the peso from being worth $1 to being worth 3.5 cents in just 17 years. Be careful what you wish for. Don’t ever trust politicians with the management of money!!!

      • Todd H. says:

        One 2018 USD is worth something like $0.02 in 1913 when the Fed was formed, so I guess we should trust them.

        What I wish for is a gold/silver standard and free banking. Is that too much to ask? :-)

        • Jonathan Vause says:

          funnily enough it’s the same neoclassical economists that you despise that are usually keenest on gold standards, and it’s probably the point they are most obviously wrong about

        • Wolf Richter says:

          There is a difference: Someone born in 1913 would be 105 years old now. Someone born in 2001 would be be 17 now. And the peso is measured against the also declining dollar. So in terms of absolute decline in purchasing power in Argentina, it’s even worse. And then this: the peso lost 25% over just the past few months!!

  9. Kk says:

    It doesn’t add up, surely the power of the market should mean those who do a poor job, believe what executives tell them, give a clean bill of financial health to all their clients, and don’t do the job properly will be replaced by clean living, honest and hard working auditors ready to challenge executives claims, dodgy-deals and outright frauds?

  10. alzur says:

    Sure, prosecute the auditors for negligence. But this does not solve the basic problem. The problem is the entire Ponzi scheme and its systemic fraud in the form of shorts, hedges, derivatives. Stop this fraud structure and the means to conduct fraud is eliminated.

    • Greybeard says:

      Actually the fraud in the article had nothing to do with the instruments you mentioned. It is the more classical accounting fraud of papering over non-performing loans and overvaluing (or just making up) assets used as loan collateral.

      You may have a point regards trading instruments, but to inject your point into an unrelated issue is trolling.

  11. Gershon says:

    Until the regulators, enforcers, and auditors who have enabled and abetted systemic financial fraud are charged with felonies and given lengthy prison sentences, along with their bankster accomplices, nothing is going to change.

    • McMike says:

      Not to let auditors off the hook, but cracking down on auditors will not solve the problem. The failure of the audits is a symptom, not the disease.

      It is like going after the mafia by cracking down on crooked low level cops.

      • RagnarD says:

        So is complaining about Greenspan/Bernanke/Yellen at FED.
        These folks figureheads. How do they get nominated/voted in/maintain power? Did they buy their way into positions of power?
        Clearly not.

        Thus they are simply smart monkeys doing what is expected of them by the *real* powers that be. Whether they are bought or simply to dim to understand anything that ever came out of the pen/mouth of Grant/Faber/Schiff, etal., I don’t know.

        But the “solution” is not railing at the FED/ Fed employees for doing the “wrong” thing. Because they are doing what they were hired to do. The solution is the American people demanding our politicians / government eliminate the FED.

        But that becomes a VERY basic Democrat vs Republican question.
        If the existence of the FED facilitates the printing / manipulation /devaluation of the USD, then which 50% of the population is going to vote for that? Or put another way, which 50% of the population is going to vote for the welfare fantasy to continue? A fantasy only possible via money printing.

  12. Doug Powell says:

    Winner is: La La Land!!

    • TheDona says:

      Thanks for the laugh Doug. That is the first thing that popped into my head.

  13. Bruce says:

    I can almost see the astonishment on Steve Carell’s face as he interviews those auditors in the upcoming movie, “The Bigger Short”…..

  14. Tinky says:

    “PwC is the same audit firm that confidence-inspiringly and diligently performs the annual audits of the financial statements of each of the 12 regional Federal Reserve Banks – such as the New York Fed and the San Francisco Fed – along with the combined financial statements of the Federal Reserve System.”

    The above, Wolf, is an example of why some of us, in spite of having only a fraction of the knowledge of economics that you have, are extremely cynical about the Fed, and wouldn’t be at all surprised to learn that it has in the past, and continues to prop up failed banks and broader markets in ways that it would never choose to reveal.

    • Drango says:

      The Fed says all of the too big to fail banks passed the stress test with flying colors. It sounds like the Fed is employing a lot of college interns.

    • Dan Romig says:

      Citigroup borrowed $2.513 trillion from the Fed between December 1, 2007 and July 21, 2010 according to the GAO, and yes, the Fed and Treasury tried to keep these trivial little details secret.

      The usual suspects were involved:
      Treasury Secretary Hank Paulson
      New York Fed President Timothy Geithner
      Fed Chairman Ben Bernanke
      FDIC Chair Shiela Bair
      Comptroller of the Currency Joe Dugan

      Would I lie to you?
      Would I lie to you honey?
      Now would I say something that wasn’t true?
      I am asking you sugar
      Would I lie to you?

      • Todd H. says:

        Gotta keep the 1% the 1%, right? Just doin’ God’s work here people.

      • Robert says:

        Great post. If you could read just one commentary about the economy and business, it is Wall Street on Parade. If we only had a few Russ and Pam Martens in government. (throw in Harry Markopolos to run the SEC.)

  15. blindfaith says:

    “So when things get complex – and there surely are very complex and immense transactions at the Fed – and senior auditors can’t figure out what they’re looking at and can’t make heads or tails of it, they’re sending in a “college-aged intern” to paper over it?”

    Dear Wolf…seems no one learned a damn thing from Enron. Oh, that’s right, things are different this time.

    To many making to much money, all connected to each other one way or the other….on the board, marriage, relative, old school chum, blackmail, religions, same club, etc.

    • Setarcos says:

      Perhaps there is a simpler explanation as well. Large frauds originate with people who hold much more power than the people who are charged with rooting it out. Whistle blowing is risky on many levels, so it’s typically a poor risk/reward scenario.

      Imagine how much fraud occurs within the various Govt agencies. Any whistle blower hero names come to mind?

    • Mel says:

      Perhaps excessive complexity ought to be taken as a red flag. If there’s something the auditor can’t explain, it might well be that there’s no good explanation for it. Fraudsters *are* trying to hide their actions, after all.
      But I can see how getting your customer taken down for fraud might not get you payed.

      • McMike says:

        “I cant figure this out” is code for “I wont sign off on this.”

        Thats WHY they sent in a junior person. Someone naive enough to sign off.

  16. Guy M Daley says:

    Read most of the comments and they all lean towards incompetence of the auditors as if fraud was completely out of the question – inconceivable.

    Lets say owners wanted a specific outcome from the audit and they got together with owners of the auditing firm and said, look, this is what we need, can you make it happen?

    Audits are a sham. They satisfy certain rules and regs like checking off a box. That’s about it. Auditors can be bought and sold just like politicians, which is why auditing the Fed is completely nonsense. You could NEVER find an auditor that wasn’t unduly influenced.

    If the #1 and #2 of the FBI and the attorney general of the US can be bought and sold its horribly naive to think that auditing is always going to be above the table.

    • Kent says:

      Auditors responsibility is to those who hire them: corporate management.

    • TheDona says:

      “Make it happen” is what is going down in Silicon Valley now. Read about PwC Whistleblower. Long but enlightening read:

      If you Google search all of the Auditing firms scandals, including C&L (whom PwC merged with almost 20 years ago), they are all dirty, rotten, scoundrels.

      On the other hand….do we really want to find out what a house of cards it all is? I for one do not want my obligatory retirement “investments” to fall to 10 cents on the dollar, which is probably the real worth.

      Fines will whiningly be paid and business will carry on.

  17. Setarcos says:

    A fraud this large that went on for several years could have also been detected by the bank’s regulator. Thinking that was probably the Office of Thrift Supervision in the case of Colonial or perhaps the OCC.

    But then again, I’m trying to think of examples of a bank regulator taking on an unsafe/unsound bank ahead of time prior to 2009.

  18. DK says:

    Regulatory capture and audit capture. I guess we’re all pretty much captured now.

    • HowNow says:

      I agree. There are many who have undying faith in “free markets”. It’s a new religion but without a god. No, I’m wrong; the invisible hand is god’s hand, that’s why no one can see it.

      Regulatory capture is the “free market” in operation. Famous quote from Captain Laissez Faire: “Let them do as they please”. Corporations take over regulation through the revolving door of regulators/legislators/lobbyists/corp. executives. That’s the problem with government. It’s good until it goes bad = regulatory capture. Many of the ninnies who contribute here think that “free markets” are the solution and that government is the problem. They want the military, the police, the fire service, teachers, streets without pot holes, border control, safe water, trash collection, etc. and they expect them to be ethical. In this case, it’s the egg first, then chicken later. The ninnies should be shipped to Russia where they can watch klepocrats gobble up all assets and get a clear picture of free markets in action. Reasonable regulation… is that humanly possible? The former nominee for the Supreme Court, Bork, said that if two companies are competing in a market, that’s a free market – and he wants to protect free enterprise! So with those kinds of thinkers being installed by their oligarch masters – what would any sane person expect. If you believe in the invisible hand, you should believe in the tooth fairy. Soupy Sez: “Be true to your teeth, or they will be false to you!” If it’s invisible, you should believe it.

      • Setarcos says:

        Here’s something for all us ninnies to ponder ….

        “Of all tyrannies, a tyranny sincerely exercised for the good of its victims may be the most oppressive. It would be better to live under robber barons than under omnipotent moral busybodies. The robber baron’s cruelty may sometimes sleep, his cupidity may at some point be satiated; but those who torment us for our own good will torment us without end for they do so with the approval of their own conscience.” Lewis

  19. Lune says:

    Sarbanes-Oxley was passed in 2002 after Enron, and this is the *first* time it’s been found to have been violated? That’s the real tragedy.

    When will they go after Jamie Dimon for the London Whale, a trading fraud which occurred under his watch? SarbOx was specifically designed to keep executives from evading responsibility by saying they had no knowledge of what was going on in their company. Yet that’s precisely what Dimon used as his defense. I guess the only difference is JP Morgan is too big to fail…

    • Wolf Richter says:


      The way I understand it, it was the first time than an auditor was found negligent under the act. But the act covers other entities, including executives, and any court decisions on those would be a different matter.

  20. Ambrose Bierce says:

    This is like blaming Toyota because the gas pedal sticks on a few cars. This is not really going anywhere until you prove that their business is providing faulty audits. You might bring down PWC, replace it with XYZ and a lot of the same people would just move over to the new company. A lot of the processes Enron used are now common practice? Government taking an entire war off balance sheet? I am of the OP that accountants run the world (like scribes used to run the church) they make decisions which other accountants look at and say, gee why didn’t I think of that? Who audits the accountants? The markets do, and when SHTF you know you failed the audit.

  21. Anon1970 says:

    When Arthur Anderson went under because of Enron, it didn’t just hit the senior partners. Thousands of the lower level employees also lost their jobs and benefits and whatever money they might have had in deferred compensation or profit sharing plans. I think an effort was made not to take down another large accounting firm. Once upon a time, there was the Big 8. Now its down to the Big 4.

    • Laughing Eagle says:

      Anon1970 I agree. Look at the 2008 collapse. Removed Lehman, Merrill Lynch, Bear Stearns. I think the next attack is Wells Fargo, but they are no worse than the rest. But Morgan and Goldman get help from Fed on passing their stress test.
      The more I read the more fraud I find occurring or is implicated in the paper shuffle thru Wall Street.

    • Beans Baby says:

      It also didn’t hit any retired senior partners who had cashed out in recent years prior to Enron collapse.
      I once had an AA senior partner describe the “risk” arm of audit to me as what the company being audited risked by conducting their business in the manner they chose. In other words, the risk of being caught and what the cost of being caught would do to the balance sheet. He basically said all business was fraudulent to some degree and AA risk put a finite number of $’s that should be available in the event that fraud enforcement was enacted.
      I am not an accountant but isn’t the risk arm separate from the audit arm in big firms? If so, the whole accounting business is set up to protect the business of accountants.

  22. Gene says:

    I was an auditor for 32 years with a federal government auditing agency. It was rewarding, interesting work. Then, around 2008, the amount of time that went into audit planning multiplied by a factor of about four. The risk assessment, a required part of the audit program under Generally Accepted Government Auditing Standards, done at the beginning of the audit, started to require as much time as the entire audit used to take. Carefully completed risk assessments were rejected for trivial reasons. Aside from that, the agency focused more of its resources on auditing systems and the internal controls within those systems, and less on the actual transactions. Auditing in this environment is far more difficult than most on the outside realize.

  23. Gershon says:

    In a time of universal fraud, possession is 9/10s of the law.

  24. Comaboy says:

    Let’s see some documentation in support of PwC performing audits of the Fed.
    According to my sources at the Fed, KPMG performs (and has been for the past 2-3 years) audits of each of the 12 districts and the Board of Governors.

Comments are closed.