Ten years after the Sarbanes Oxley Act

We have a very interesting speech by Lewis H. Ferguson, Board Member (PCAOB), that gives us a very good understanding of where we are, 10 years after the passage of the Sarbanes Oxley Act.

“It has been 10 years since the passage of the Sarbanes-Oxley Act and the Board’s creation. I served my first tour of duty at the PCAOB as General Counsel from 2004 to early 2007, shortly following the passage of SOX. One of our early and high priorities at the Board was to establish a cooperative relationship between the Board and the state boards of accountancy because we realized that the Board shares a common mission with the state boards and that, working together, we can better protect investors and strengthen the auditing profession.

Currently, the PCAOB shares its detailed inspection reports, including the non-public portion, with thirty-two state boards of accountancy where the inspected firm or individual holds a license to practice and as long as the state board has acknowledged in writing its awareness of the Sarbanes-Oxley Act’s confidentiality restrictions. The Board also sends a letter to the other state boards of accountancy with the public portion of the inspection report for the accounting firm that is licensed to practice in that state and informs that board that it can receive the non-public portion of the inspection report if it signs the PCAOB acknowledgement and agreement form.

In addition, the PCAOB and the state boards of accountancy have been able to share certain information relating to PCAOB and state board enforcement actions. We also appreciate the letters that NASBA sent to Congress earlier this year in favor of legislation that would allow the Board to make disciplinary proceedings open to the public.

Moreover, the PCAOB benefits from the comment letters that NASBA and state boards of accountancy regularly submit on its proposals and concept releases. The insightful comments assist the Board in ultimately developing a better standard or rule. Additionally, a NASBA representative has served on the PCAOB Standing Advisory Group since its inception and a NASBA representative frequently participates in the Board’s standard-setting roundtables and public meetings.

Most recently, for example, Gaylen Hansen provided his thoughtful views on the question of mandatory auditor rotation at the Board’s third public meeting on auditor independence, objectively and professional skepticism in Houston.

Role and Relevance of the Auditor

The role of the independent auditor has evolved over time. This is to be expected because we live in a commercial and financial environment that itself is continuously evolving. Auditors have most often been subject to intense scrutiny following economic crises like the great depression of the 1930s, major financial frauds like the Enron and WorldCom cases in the early 2000s, and the global financial crisis and recession of 2008-2009. In such cases, investors, regulators and the public ask “Where were the auditors?” implying that the auditor should have warned them beforehand that a crisis was imminent.

Whether or not that is a realistic expectation of the role of auditors, the improvement of audit quality is central to the Board’s mission. Since I joined the Board in February 2011, the Board has had an opportunity to meet with many parties who have an interest in enhancing and improving audit quality, including investors, preparers of financial statements, auditors, academic experts and regulators both in this country and abroad, and to listen to their views, ideas and concerns.

One thing has become evident to me from these discussions. There is a widespread sense, following the global economic crisis of 2008 and 2009, that existing financial reporting mechanisms of which the auditor’s report on the financial statement is a central pillar failed in many cases to give any advance warning to investors and others of the risks that led to the failure or near failure of many systemically important institutions, particularly financial institutions. Many such institutions both in the U.S. and abroad received clean audit reports only months before they required massive government bailouts. Many commentators have argued that a financial reporting system that could allow the risks and underlying problems that led to the crisis to go unreported must be fundamentally broken.

Since the Board’s mandate is the oversight of auditors and not issuers or audit committees, we have focused on the role of the auditor and whether it needs revision. Specifically, we have concentrated on how audit quality can be improved, on how the auditor’s independence, objectivity and professional skepticism can be strengthened and on how the work of auditors can be made more transparent to the investing public.

In this regard, the Board has undertaken a number of initiatives — dealing with communications between auditors and audit committees, the auditor’s reporting model, auditor independence, and transparency — which, depending on their outcome, have the potential to change the auditor’s relationship both with the issuer and users of financial statements in fundamental ways.

Enhancing the Auditor and Audit Committee Relationship

Most recently, in August of this year, the Board adopted Auditing Standard No. 16, Communications with Audit Committees. The new standard establishes requirements that enhance the relevance and timeliness of the communications between the auditor and the audit committee, and is intended to foster constructive dialogue between the auditor and the audit committee on significant audit and financial statement matters.

Auditing Standard No. 16 provides a definition of the term audit committee, retains or enhances existing communication requirements, and incorporates certain SEC auditor communication requirements to audit committees, such as the requirement to communicate all critical accounting policies and procedures.

The standard also incorporates new communication requirements that are generally linked to performance requirements in other PCAOB standards, including communications about the overall audit strategy, information about specialized skills required in the audit, the use of the company’s internal audit function in the course of the audit, difficult or contentious matters with respect to which the auditor believes it was necessary to consult outside the audit team, the auditor’s evaluation of going concern issues, and any departures from the standard auditor’s report.

While the standard establishes certain requirements regarding auditor communications to the audit committee, it does not preclude the auditor from providing additional information to the audit committee. The standard sets the minimum but not maximum standard for communications. Nor does the standard preclude the auditor from responding to audit committee requests for additional information from the auditor. If audit committees want additional or more detailed information about particular topics, their members remain free to ask their auditors any questions, and request information they believe would help them understand the audit and the finances of the companies they oversee.

Some commentators have questioned the need for such a standard, contending that audit committees already routinely seek and get this information and that setting up requirements will inevitably lead to a “check the box” approach to audit committee communication. The Board disagrees. Through our inspection work, the Board has come to understand that there exists a wide range of expertise and sophistication on audit committees — there are some audit committees, particularly in the largest companies, whose members possess great technical and industry expertise. There are many other audit committees, however, whose members are less experienced or do not have the technical expertise to understand complex financial and accounting matters. For the latter group, the Board believes more robust communication between the auditor and the audit committee can be useful.

We hope that the new standard and its requirements will provide greater uniformity to the communications between auditors and audit committees of public company and will insure that all audit committees are informed about some of the most important elements of the auditor’s work and findings with respect to the issuer’s financial statements. We believe that this can be a significant contributor to better corporate governance of the issuer.

The standard is presently awaiting approval by the Securities and Exchange Commission. Once approved by the Commission, it will become effective for all audits of fiscal years beginning on or after December 15, 2012.

Additionally, on August 1, 2012, the Board issued a release to provide information to audit committees about its inspection program and the meaning of PCAOB inspection findings. The release discusses the meaning and significance of audit deficiencies described in the public portion of an inspection report and provides a basic description of the way that audit quality control criticisms are framed in portions of an inspection report that are, at least initially, nonpublic.

The release also highlights certain areas of inquiry that audit committees may wish to discuss with their auditors, including, for example, whether the audit overseen by the audit committee was selected by the PCAOB for inspection and whether any findings were made; potentially relevant inspection findings with respect to other audits performed by the audit firm; the audit firm’s response to the PCAOB findings; and the audit firm’s remedial efforts in light of any quality control deficiencies that may have been identified by the PCAOB.

The release also provides the Board’s perspective on certain types of assertions made in the public portions of the audit firms’ responses to the inspection reports and possibly in discussions with audit committees, including assertions that characterize the criticisms as differences of opinion in professional judgment or documentation deficiencies rather than deficiencies in the performance of audit procedures to obtain sufficient competent audit evidence.

The Board hopes that this report will encourage audit committees to inspect PCAOB inspections with their auditors and will assist audit committees to better understand the Board’s inspections reports.

Auditor’s Reporting Model

Another standard-setting project that the Board has undertaken is the possible revision to the auditor’s reporting model. I believe that this is potentially one of the most significant projects the Board has ever undertaken.

Following extensive outreach by PCAOB staff, the Board, in 2011, issued a concept release in response to commonly and vocally expressed dissatisfaction on the part of investors and other financial statement users with the current form and content of the auditor’s report. This dissatisfaction is not new but has been expressed by financial statement users for decades and has been commonly termed “an expectations gap” — that is, a gap between what users expect and what the audit report delivers. What is new, however, since the financial crisis is the volume and urgency of the criticism of the current reporting model.

The current auditor’s report provides a general level of information for investors and financial statement users — that the issuer’s financials statements and footnote disclosures are presented fairly in all material respects and in conformity with the applicable accounting framework. Unfortunately, this pass/fail model — while useful generally – does not provide the types of specific information that investors and other financial statement users are seeking.

Commerce grows ever more global and financial transactions grow ever more complex. Those facts, coupled with the evolution of accounting standards away from historical cost accounting toward fair value accounting means that financial statements and footnote disclosures are now comprised of numbers that are based on management’s estimates of many things such as the fair value of assets and liabilities rather than amounts that can be measured precisely. The increasing use of complex financial instruments such as derivatives and the global operations of many public companies with their exposures to currency fluctuations have made financial reporting and financial statements much more complex than in the past, and in some ways, imprecise. Many of these items are very difficult to value or can only fairly be valued in ranges.

Auditors today, for example, must test the valuations and range of estimates in these financial statements, ascertain if they are fairly presented, and express their views in the auditor’s report. Unfortunately, the truncated pass/fail model only conveys the auditor’s final conclusion to users of the financial statements that the financial statements are or are not fairly presented and gives little or no clue to the many analytical processes and risk assessments that underlie those conclusions.

We know that auditors, assuming they are doing their jobs, bring expertise and experience to the audit and learn a tremendous amount about the company’s financial condition during the audit. The auditors read, review, test, and corroborate the financial information presented by management. One of the auditor’s most important tasks is to identify and test those areas of the financial statements where the risk of material misstatement is highest.

The auditors formulate their views of this financial information, communicate and discuss with the audit committee the results of testing and the significant risks and issues identified during the audit, and determine if the financial statements and footnote disclosures are presented fairly in all material respects. With a well informed and skilled audit committee, these discussions are often detailed and robust. Unfortunately, under the present auditor’s reporting model, this information and these communications are largely masked from public view.

In considering this issue, the Board is aware of, and sensitive to, the fact that the financial statements are the responsibility of management and the board of directors, and we are fully cognizant of the risks involved in having a third party, such as an auditor, express subjective views about a company’s financial condition or prospects.

The concept release presented four different alternatives for changing the auditor’s reporting model: requiring and expanding the use of emphasis paragraphs, adding an auditor’s discussion and analysis, adding auditor assurance on other information outside the financial statements, and clarifying the language in the standard auditor’s report. The alternatives are not mutually exclusive, and a revised auditor’s report could include one or a combination of these alternatives or elements of these alternatives.

The Board also held a roundtable to obtain additional views on the different alternatives and has, to date, received over 150 comment letters.

As with any proposal that contemplates substantial change, there is a wide diversity of views. There was also widespread agreement that the auditor’s report could be made more relevant and useful to investors and other financial statement users. The disagreements focused on how much change is appropriate and varies to a large extent on the user (e.g., investor, preparer, audit committee member, or accounting firm).

There was almost universal support for retaining the pass/fail model for its concise and useful message and ease of comparability. Investors, however, noted that the pass/fail model should be supplemented by additional auditor reporting either in the current auditor’s report or in a separate supplemental report (e.g., auditor’s discussion and analysis).

Preparers and board members noted that the existing pass/fail model is sufficient for purposes of the existing financial reporting framework and that detailed discussions about the financial statements should be left to the company. These commenters noted that management is the most appropriate source for providing additional information regarding the financial statements because management has the most complete and detailed knowledge of the company’s transactions and activities. They also pointed out that the U.S. securities laws assign the legal responsibility to prepare the financial statements and required SEC filings to the company not the auditor.

Preparers and board members were strongly opposed to the auditor discussion and analysis alternative in the concept release contending that it would change the long standing and, in their view, highly functional relationship between the company and its outside auditor as well as raising the possibility of “dueling disclosures” between the auditors and management. This would confuse securities markets and ultimately force management to adopt the auditor’s view on any conflicting issues. They were also concerned that such a report would impede the free and candid flow of communication between management, the audit committee and the auditor. Auditors generally opposed this approach citing the levels of review and extra time it would take.

Investors took a different view. They generally believe that auditors develop a deep and expert knowledge of the financial condition of the companies they audit and have views about the risks of misstatement in the financial statements as well as the quality of the company’s financial reporting. These investors believe that more disclosures about audit risks and possibly about the uncertainties inherent in estimated amounts could be very useful. Perhaps most important to investors, the auditor provides an independent third-party assessment of the company’s financial condition. This does not necessarily reflect a distrust of management’s disclosures, but a strong desire to have an independent and expert view as well because management’s disclosures are inevitably self-serving.

Another approach that enjoyed more general support is the use of emphasis paragraphs in the audit opinion in which the auditor without offering his or her own gloss on the disclosures would emphasize areas of the financial reports and footnotes that deserve special scrutiny by the user of the reports either because they are areas of significant audit risk or because they are subject to management estimates and uncertainty. Some such disclosures would likely be mandatory and some could be optional. A concern with this approach which is, incidentally, already in use in some other jurisdictions including France, is that the disclosures could become boilerplate conveying little useful additional information. The Board is actively considering approaches that would avoid the boilerplate problem perhaps by requiring the disclosure to be tied to a discussion of specific facts in the financial statements to which they referred.

Other approaches that were widely approved by commentators are some expansion of the auditor’s opinion to cover parts of the financial disclosures apart from the financial statements and footnotes such as discussions of critical accounting policies and estimates in the management discussion and analysis.

Finally, commentators generally supported some clarifications of the definitional provisions of the auditor’s report such as the definition of terms such as “reasonable assurance” and the auditor’s responsibility for detecting fraud.

As you can imagine, these are not easy issues to resolve. The auditor’s report has not significantly changed since 1940 and it is not because standard-setters haven’t tried. The Board staff is working diligently on drafting a proposed standard for the Board’s consideration. One of the things the staff is considering is combining certain portions of some of the alternatives. The Board staff also is closely monitoring the IAASB’s project on the auditor’s reporting model, as well as the European Commission’s proposed legislation.

Improving Transparency in Audit Reports

As you are aware, the typical audit report for a U.S.-listed company includes the signature of the accounting firm that issued the audit opinion and the geographical location of the firm’s office. In this era of global networks firms, that signature does not tell the full story. An audit report on a multi-national company may carry the signature of one audit firm, but gives the reader no hint about the key participants in the audit such as the identity of the lead engagement partner or whether portions of the audit were conducted by one or more affiliated firms in the global network or by another auditor. The audit report also gives no information about how the audit work was allocated among firms.

In October 2011, the Board issued proposed amendments to its auditing standards to improve the transparency in the auditor’s report by requiring the auditor’s report to identify the audit engagement partner and to disclose the identity of any other audit firms or individuals that participated in the audit. The Board’s proposal would identify the engagement partner in the audit report but not require the partner to actually sign the report.

This is not a new concept and there are several countries around the world, including in Europe, that require the audit engagement partner to sign the auditor’s report. The thinking behind the Board’s proposal is that in most audits there is an individual, the audit engagement partner, to whom the client looks primarily in dealing with the audit. Audit committees are often actively involved in the choice of the lead engagement partner when the mandatory partner rotation occurs. As a result, or so the thinking goes, there is no reason to mask that person’s identity from investors. That being said, this proposal has been controversial. Some critics have said that the audit is a collective effort and no single individual should be singled out. While investors have stated that they were supportive of the additional disclosure, other commenters have voiced concerns about possible liability consequences of naming the audit engagement partner and whether a named partner would have to consent individually to the filing of the audit report with the SEC under SEC rules.

These amendments, if approved by the Board and the SEC, would serve two purposes. First, they would give investors more information about the identity of the lead engagement partner and the firms that are actually performing work on the audit that many investors have told us they want. In addition, identifying such firms would make publicly available the names of firms that have provided more than 3 percent of the total audit hours but are located in jurisdictions where the PCAOB cannot yet conduct inspections. Investors can then make a more informed decision about the quality of the firms participating in a company’s audit.

Independence, Objectivity, and Professional Skepticism

I would be remiss if I didn’t touch upon today the Board’s most controversial project; an exploration of ways to improve the auditor’s independence, objectivity and professional skepticism.

Last year the Board issued a concept release to solicit public comment on ways to enhance the auditor’s independence, objectivity and professional skepticism. Among the approaches on which we sought comment was mandatory audit firm rotation after a period of time.

The concept release also sought comment on whether there are other measures short of firm rotation that could meaningfully enhance auditor independence, objectivity, and professional skepticism, such as mandatory tendering after a certain period, joint audits with another firm, or other solutions. As was to be expected, this proposal was highly controversial.

What, you might ask, would prompt the Board to raise a subject that could be foreseen to be so controversial, indeed, even inflammatory? Several factors influenced our thinking. There is an inherent conflict built into our system of auditor compensation where the company whose financial statements are being audited hires, fires and pays the auditor.

Second, the average tenure of the auditors of the Fortune 100 companies is about 45 years, with some much longer. IBM, for example, has had the same auditor for more than 100 years, and Coca-Cola for 91 years. Some have questioned whether tenure of that length by itself, with its implication of a large stream of audit fees continuing into the indefinite future, undermines independence.

The Sarbanes-Oxley Act imposed the requirement that audit engagement partners must rotate every five years, and opponents of mandatory rotation cite this requirement as evidence of sufficient protection against “auditor capture” by the audit client. Proponents of mandatory rotation ask whether any new audit engagement partner of a major client of his or her firm that is a long standing client of the firm can reasonably be expected to take any action that would threaten the client relationship that may be decades long. Losing such a client relationship could well be career ending for any auditor on whose watch it happened.

Perhaps most important, PCAOB inspections for the past nine years have revealed that a recurrent theme where audits fail is a lack of sufficient auditor skepticism, and the client pays model coupled with long auditor tenure may, at least in part, be responsible for that.

The Board received more than 600 comment letters with the majority of the commenters opposing mandatory firm rotation. Not surprisingly, almost all issuers and audit firms oppose mandatory rotation arguing that it would diminish the role of the audit committee and arbitrarily force auditor change even if the auditor is doing a good job. Mandatory auditor rotation is common in the U.S. among not-for-profit organizations, including some of the nation’s largest pension funds and government agencies, and representatives of those organizations, as well as representatives of consumer groups, strongly favor mandatory rotation. Some commentators suggested confining auditor rotation to certain categories of issuers such as systemically important financial institutions.

Other commenters have advocated a package of reform solutions short of mandatory rotation representing a combination of measures, including, but not limited to, mandatory retendering of the audit after a period of years, further strengthening the audit committee, strengthening existing independence rules and auditing standards, improving audit firm culture and systems of quality control, and enhancing the PCAOB’s inspection and enforcement programs.

In light of the varied view points and the recommended alternatives presented in the comment letters, the Board decided to hold public meetings to obtain further input on the matters discussed in the concept release. To-date the Board has held three public meetings and has heard from almost 100 speakers on this topic.

The Board also is not alone in analyzing this issue. The European Commission, through a proposal issued in November 2011, is considering requiring mandatory firm rotation every six years or every nine years for joint audits. That proposal is currently being debated in the European Parliament and Council. The lower house of the Netherlands parliament has also adopted a bill requiring mandatory firm rotation every eight years. Additionally, last month, the U.K. Financial Reporting Council changed its Corporate Governance Code to require all FTSE 350 public companies to put their external audit contract out to tender at least every ten years. If the audit committee chooses to retain their auditor after the retendering, the Code requires the audit committee to explain why in a detailed public report.

Also, there are several countries, including Italy, Brazil and India, that already require mandatory firm rotation and some countries require rotation for certain types of companies. The People’s Republic of China, for example, requires rotation of the auditors every five years for its major banks. Clearly this is an issue that has attracted world-wide attention and everyone concerned with the audit business will be following it closely in the coming years.

How to enhance the auditor’s independence, objectivity, and professional skepticism is a complex issue. Experience both in the U.S. and elsewhere has shown that when a company changes auditors annual audit fees typically decrease. One recent report noted that at China’s three large state-owned banks that rotated this year, auditors saw an average reduction of 22 percent of the annual audit fees. Assuming previous audit fees were not unreasonable, the question arises whether such fee reductions are loss leaders to obtain business that will be adjusted in the future or whether audit quality will suffer as profit margins are squeezed. We hear constantly from preparers that they want more experienced auditors to serve on their engagements. We also know that one way to improve audit quality is to have auditors spend more time performing the audit and focusing on the critical areas and significant judgments and estimates. Our inspection findings have shown that in many cases audit deficiencies are related to insufficient time spent on particular audit areas.

As should be apparent, this is a very difficult issue and the Board will proceed with deliberation on it.

International Cooperation

At this point, I am going to switch gears and spend the remaining time on international cooperation with other audit regulators.

The PCAOB cooperates closely with audit regulators outside the United States, and the scope of that cooperation is extensive. Since 2005, we have conducted 338 inspections of PCAOB registered firms in 38 different countries.

We have cooperative agreements with 14 foreign regulators where we either conduct joint inspections or share inspection findings with regulators in those jurisdictions. We are also actively negotiating such agreements with regulators in a number of European countries and others around the world.

We have found that joint inspections are particularly useful and have conducted them with regulators in Canada, Switzerland, the United Kingdom, Germany, Norway, Spain, and the Netherlands. In these inspections, we have faced and resolved difficult data protection issues that are of great concern to regulators in the European Union and resolved confidentiality concerns that Swiss regulators have raised.

The joint inspections have demonstrated that with a cooperative approach many obstacles can be overcome. In joint inspections each regulator learns from the other and we are convinced that these inspections have improved regulatory oversight both by the PCAOB and by our foreign counterparts.

IFIAR

One of the ways the PCAOB shares experiences and its knowledge with other audit regulators is through its work in IFIAR, the International Forum of Independent Audit Regulators.

IFIAR, comprised of independent audit regulators, was formed in September 2006 to provide a forum for regulators to share knowledge of the audit market environment and the practical experience gained from their independent audit regulatory activity. Only regulators that are truly independent of the auditing profession are eligible for membership which has grown steadily to 44 members today with over 10 candidate members in various stages of the application process.

The United States has come to play a leadership role in IFIAR and I was honored recently to be elected Vice-Chair of the organization. IFIAR holds annual plenary meetings at which regulators from around the world meet to exchange information on a variety of topics including general inspection findings, standard-setting initiatives and cross-border cooperation. We just concluded our twelfth meeting in London earlier this month. In addition, there are five working groups that meet more frequently and focus on specific issues like standard setting, international cooperation, investor concerns, inspections training and public policy.

One of the most important is the last, the Global Public Policy Committee Working Group, that meets three times each year with the leadership of the six global network audit firms to discuss issues of concern to the regulators and the firms. IFIAR also conducts an annual inspection training workshop for audit inspectors from around the world.

For the first time this year, IFIAR has surveyed its members about their audit inspection findings. Almost all IFIAR members responded to the survey and while the results are presently confidential, I can tell you that a striking result of the survey is that other regulators around the world seem to be finding the same types of defects in their inspections that the PCAOB is finding, particularly deficiencies in auditing fair value measurements, testing internal controls, revenue recognition and engagement quality control reviews. IFIAR is currently working on a summary of the report to be published by the end of the year.

You might ask why an organization like IFIAR is important. The short answer is that it enables individual regulators to get a better window on the global landscape of audit practice and financial reporting. This is important because the world’s largest enterprises — those that represent the largest share of global economic activity and shareholder wealth — operate globally.

Not only do they sell products globally, but increasingly they purchase raw and component materials, manufacture, distribute, and do research and development globally. One only needs to look at some of the latest signature industrial products, like new automobiles, computer and smartphone products, or the Boeing 787 airliner to realize that these products are produced from designs and components sourced and manufactured in many different countries.

A global company, perhaps operating in more than 100 countries, also has financial reporting activities in many, if not all, of those countries. Any regulator, confined to a view within its own borders, can only see a portion, and often a small portion, of the activities and risks of such an enterprise. Cross-border regulatory cooperation, working together and sharing information, is vital to our common mission to improve the protection of investors who rely on auditors to assure that the financial reports of publicly traded companies are transparent, complete and fairly stated.

Just as the largest corporations in the world have become increasingly global in their operations, their auditors must be able to conduct audits on a global basis. The largest audit firms have grown globally along with their clients.

But unlike their corporate clients, which usually operate globally through a centrally controlled structure of parent and subsidiary entities, the global audit firms operate as an affiliation of individual audit firms. They are organized and operating under the laws of different political and regulatory jurisdictions joined together in networks where they share clients, training, audit methodologies, and quality assurance practices.

In the audit of a major global corporation, a number of different auditing firms, operating under a single trade name, will cooperate to perform the audit of the corporation’s global operations. Today, the auditor’s report on such a corporation is signed by only one firm in the network and does not reveal whether other affiliated firms participated in the audit or the extent of their participation.

The reality of today’s global business environment means that regulators around the world must do the same thing. We must cooperate effectively with each other if we are to ensure that audit quality remains high and that investors are protected.

China

Now, let me turn to China. As you are probably aware, in the past year or so, alleged serious financial frauds and attendant accounting problems have been disclosed involving a number of China-based companies whose securities are registered outside of China, particularly in the United States, Singapore and, to a lesser extent, Europe.

Not more than a decade ago, Chinese firms began to access foreign capital markets. Two types of Chinese companies sought access to U.S. capital markets, smaller enterprises that had difficulty accessing the very restricted Chinese domestic capital markets and some of the largest state-owned enterprises in industries such as petroleum and telecommunications. At the same time some of the largest global companies, including U.S companies, began to engage in extensive operations in China.

The smaller companies most commonly sought access to U.S. markets by merging with existing, registered U.S. shell companies in reverse mergers. The larger companies filed initial public offerings.

Beginning in the latter part of 2010, alleged financial frauds and serious accounting issues were revealed at a number of the smaller Chinese reverse merger companies. To date, 67 of these China-based issuers have had their auditor resign, and 126 issuers have either been delisted from U.S. securities exchanges or “gone dark” — meaning that they are no longer filing current reports with the SEC. Billions of dollars of market capitalization of such companies have been lost in U.S. securities markets and it is fair to say that all of these smaller China-based companies listed on U.S. securities exchanges have suffered serious losses of both market value and investor confidence as a result of the problems of other companies.

The number of China-based companies that have successfully filed an initial public offering in the United States in the past year has slowed to a trickle. We understand that smaller Chinese companies have also suffered similar adverse consequences in other non-U.S. and non-Chinese markets.

At present, the PCAOB does not have cooperative agreements with either the China Securities Regulatory Commission or China’s Ministry of Finance which share jurisdiction over Chinese accountants. The CSRC has jurisdiction over the 53 accounting firms, including the affiliates of the global network firms that are authorized to file audit reports with respect to companies listing securities on the Chinese domestic securities markets in Shanghai and Shenzhen. The MOF licenses all accountants in China and has jurisdiction over more than 7,000 accounting firms in China, including some of the firms registered with the PCAOB.

Under Chinese law, it is illegal to remove audit work papers from China. At the present time, Chinese authorities will also not permit any non-Chinese regulator to conduct inspections on Chinese soil. As a result, it is impossible for the PCAOB or other regulators to inspect China-based audit firms or to assess the quality of such firms registered with it. This limitation also applies to the affiliates of the global network firms that perform audit work on the audits of the Chinese operations of the large global companies operating in China.

In an attempt to address these problems, the PCAOB has intensified its dialogue with both the China Securities Regulatory Commission and the MOF over the past year. Both we and the Chinese regulators recognize the importance of improving audit quality and investor protection.

For the PCAOB, an agreement with China is important not only because of the risks investors face, but because of the size and rapid growth of the Chinese economy. Almost 5 percent of PCAOB registered firms are based either in China or Hong Kong, the largest group of non-U.S. firms.

Chinese authorities say that we should rely on their oversight of auditors. They have two principal concerns. The first is that any action by a foreign regulator on Chinese soil, even a mere inspection, could violate Chinese sovereignty. This concern has deep historical roots, specifically relating to the humiliations that China suffered at the hands of Western powers in the nineteenth and early twentieth centuries.

The second concern grows out of China’s very expansive state secrecy laws. There has been a concern expressed that inspection of audit work papers, particularly work papers from the audits of state-owned enterprises, could lead to disclosures of state secrets.

The question for both countries is how to conduct inspections in ways that respect national sovereignty and the legitimate regulatory goals of both countries. As mentioned earlier, we have been able successfully to navigate or balance these seemingly competing interests in a number of countries around the globe.

As a first step toward further cooperation, we have agreed on observational visits where PCAOB inspectors will observe the Chinese authorities conducting their own audit oversight activities and the Chinese could observe the PCAOB at work. The observational visits as outlined by the guidelines will be completed shortly. This is not be a substitute for a PCAOB inspection but is a trust building exercise between regulators. We hope such exercises will build trust and lead to further cooperation. The ultimate goal for the PCAOB is to achieve a level of cooperation with the Chinese authorities that will enable us to have enough information and confidence that we could issue inspection reports on those China-based audit firms that prepare or participate substantially in the preparation of audit reports filed in the United States. We believe that we share a common goal with China to enhance investor protection and hope that we will be able to achieve meaningful cooperation.

Conclusion

With the economic climate around the world remaining uncertain, this is just the time that investors most need protection. It is the duty of all of us involved in the financial reporting process, whether as preparer, manager, audit committee member, auditor, counselor or regulator to work to ensure that financial reports are complete, transparent, and fairly stated. We value the strong relationship we have developed with the state boards of accountancy in advancing this mission and look forward to continued close cooperation with you”.

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Carpet Cleaning Facts

There are so many different companies that have carpet cleaning services, however, not everyone hires people to clean carpets for them. Although at one point every carpet needs a thorough cleaning. If you are about to get a thorough cleaning of your carpets done then this is the article for you.

There are carpet cleaners available in a lot of places, just look them up on the internet and you can easily find them, for instance, look up carpet cleaner Balham, etc.

The first thing that the carpet cleaners will do is pre-vacuum your carpet, this way if there is any dirt and dust is removed so that it does not turn into the mud as it is really difficult to remove.

The next step is to remove any stains that might be present on your carpet. However, there are stains that cannot be removed even with the use of chemicals, and if a lot of chemicals is used on them it can cause damage to your carpet.

Since most of the cleaning products are alkaline in nature your carpet is washed with acidic solutions in order to balance out the pH and provide a thorough cleaning effect that will last. However, make sure that the chemicals used are suitable for the type of fiber that makes up your carpet.

You should keep in mind that not all carpet cleaning companies are giving you the same service. The cleaning affectivity depends on the type of equipment that is being used and also the type of chemicals. Try to get your carpet cleaned from a reputable source so that your money does not go to waste. Make sure that you hire a carpet cleaning service that is certified by the IICRC that is the International Institute for Cleaning and Restoration Certification.

Gym: What You Should Know Before Starting

When you go to a new place there is always that feeling of nervousness, no matter the place. Gyms are no exception when you first enter a gym you might get anxious since there are all kinds of people at the gym. No matter what time of the year you start, you might end up feeling lost or a little left out. Well do not worry too much, this article will guide you about certain things that you need to know before joining the gym.

All gyms have some unspoken rules and guidelines, if you are the newcomer you will find that out eventually, do not let it get to your head if you make a mistake in the initial stages, it is perfectly fine.

The next thing you need to know is that you should always be prepared, and by being prepared we mean that you should always carry a backpack with you when you head out to the gym, this backpack should contain an extra pair of clothing, toiletries, hair ties, and most importantly a water bottle.

Before you join any particular gym make sure that you first take a tour of the whole place and look around for all the facilities that the gym provides. You can go to any gym of your preference because, in the end, it is not about which gym you go to, it is about how much effort you put in. Think of it in this way, your gym is your local health club where you go to bring out a healthy lifestyle.

If you feel like you do not know how to work out on a particular machine, then do not get intimidated, ask your instructor to help you out with it.

How to Choose a Reliable Moving Company?

Home relocation can be a daunting step for many beginners who have not done it before, and they can be easily overwhelmed with all the responsibilities associated with this crucial phase. A do-it-yourself option might appear tempting at first, but it can be quite exhaustive for someone with no prior experience. Lifting heavy objects on your own can not only physically injure you but it might also damage your valuable items such as upholstery and kitchen appliances. This is the reason it is always better to call professional removalists whenever you plan to move out of your property, because this way all your belongings would be relocated in a safe manner. It is always important to delegate this crucial task to someone you can trust.

Many beginners are not aware about the presence of unscrupulous removalists in the market, who do not take the entire responsibility of the safety of their client’s belongings. Make sure to hire a local mover so that you can fully investigate their reliability before handing over your precious household items to a stranger. If you are looking for useful tips regarding home relocation in Los Angeles, then make sure to refer to the webpage of My Decorative now.

The cargo-haul process of your house removal company should be certified by the local transportation authorities, so that you can maximize the safety aspects of your items. Interstate movers are given special license that gives them the permission to relocate goods and items to different parts of the country. Make sure to check out the carrier number of your company, so that you can track its performance and reliability from the internet. The technicalities of these licenses vary according to each jurisdiction, as it governs specific laws and guidelines for a particular area.

Climb That Fence

Many products on the market go bad. Just like how offers expire and tickets are no longer suitable past a certain date and food will rot, so can your makeup go out of commission and using expired makeup is definitely not a good idea if you intend to not only care for your appearance, but also for your health. It can be tempting to let other people use your makeup products on the fly, but unless they properly washed their face or hands before touching the wand of your nail polish or eye liner, when they put the wand back in the container, that wand will carry any dirt or bacteria they may have had and contaminate the whole container.

If you want to make your mascara in particular last longer, then according to this article, there are a few things you can do and the first and foremost thing that it suggests is to never share your mascara and that advice is also applicable to other beauty products. Another thing to look out for in order to care for your beauty products is to ensure that they do see some usage every now and then. If you let them sit around for long periods of time without using them, their oils or other assorted ingredients have the chance to separate and they won’t be that effective anymore.

Liquid eyeliners for that reason, like mascara, should be thrown out in just a few short months according to that article. In just under 3 months no less but thankfully it provides steps and advice on ways you can make it last longer. Beauty products and especially things like mascara are expensive so having to toss them so out, even more so if you don’t use it very often, can be a difficult thing to do.

Sit Correctly at Work For a Better Time

While it’s great that you’re so focused on your job and your career, you should always make sure that you aren’t working so hard that you’re neglecting your health. If your body isn’t in top form, it’ll only slow down your performance at work. We all know this much but for some reason or the other, we get so carried away with work that we start neglecting our health. As a result, we’re always tired and fatigued. In the long run, this will affect both your ability to be focused and productive, as well as your mental health.

There are a lot of things that you can do to make sure that you’re healthy, even with such a busy and active schedule. For starters, eating healthy and getting the right amount of rest will really help. But doing just the basics won’t be enough to keep you in top form, especially with all that activity you’ve got in your life. You can rise up to your challenges by making your body stronger. Basically, working out is definitely something you should be doing if you want to stay on top of things in your day.

In addition to working out, you also need to minimize the discomforts that you put yourself through. A lot of us have really poor posture and back pains from being hunched over our desks all day. Back pains are awful since the discomfort will get in the way of you focusing on things. You can practice good posture at work by replacing your chair with one that’s got better back support. Visit www.wellnessgrit.com to learn more about what we’re talking about and all how it can help you improve your life at work and at home.

Construction Management Software 101

You have already read about how great construction project management software is and why you absolutely must have it. You are sold on the idea that this is an important investment and you are ready to turn your company into a tech savvy one. So what’s the next step? How do you proceed? Well, the answer to these questions is simple; you begin with research. We’re going to brief you about construction project management software and all that you need to know about it. Knowing more about what you are buying will allow you to make better buying decisions.

Construction office software or project management software is usually specifically made for use in the construction industry. This software provides construction companies with tools and functionality that allow businesses to carry out a variety of tasks better. For instance, there are software solutions that make the process of generating, sending, and receiving RFIs and RFPs a lot more streamlined. Businesses can generate and share requests electronically and then make historic records of them.

A really valuable feature of software solutions is that they allow companies to store data about their own performance and about their stakeholders. This data can then be used for analytical purposes in order to assess a company’s performance. This gives a company the ability to evaluate itself and improve its performance.

There are three steps to picking a software solution; first you conduct research in order to determine what kind of solutions are available in the market and what needs does a company have that can be fulfilled with a software solution. The second is to actually pick a solution. The third and final step is to integrate the system with your existing processes and provide your staff with proper training so that they can use the system properly.

Questions You Should Ask a Professional Translator

If you are finding yourself in the need of a professional translator, the thing that you must know here is that making the right decision is something that happens to be extremely important. There are situations in which you might end up with translators that are really good at the first glance. However, there are also situations in which the service you are hiring is simply not up to the mark. The right way to handle a situation like this is to ask some questions beforehand, therefore, you are going to be able to establish an understanding as well.

With that said, there are some questions that you might have in mind whenever you are hiring a translator. If you want to have the smoothest hiring experience you could possibly imagine, then we would suggest going for someone like Espresso Translations London. Right now, the focus is largely on the questions that you should ask, so let’s have a look.

What Are The Charges?

The first question that you should ask is about the charges. Whenever you are hiring a professional, you can ask them what the charges are. This is certainly an important task as there are situations in which you end up hiring someone who charges a lot more than what they can provide.

What is The Average Duration?

Another question that you should ask is about the average duration. This is certainly important for anyone who wants to make the most of the situation at hand. If you are looking to make things easier and smoother for themselves, then answering them this question is more important than anything else that might come in the way. It is always important to make sure that you are asking about the duration for your own convenience.

The Key to a Good Criminal Defense

When you have a criminal case pending, the most important thing that is going to be on your mind at this point in time is trying to prove to everyone that you are not the person that did all these terrible things, and that you need to find a way to make it so that you would have more options in terms of truly allowing yourself to get past what you have currently ended up suffering all in all. If you want to build a good defense for yourself, you should hire a criminal lawyer but you should also try your best to come up with some kind of alibi that you would be able to use in order to tell the people that you are pleading your case to that you could not have done what you did because of the fact that you were busy doing something else and that there is proof that can show that you were actually nowhere near the scene of the crime.

Your lawyer is probably going to want to help you out with this because of the fact that sometimes when you give an alibi it can unintentionally end up conflicting with something that you said before, and when you have this sort of feeling it has the potential to allow you to be less inclined to listen to what anyone else might be saying. Make sure that whatever your alibi is, it has been thoroughly vetted by your lawyer in order to prove to you that you did not manage to allow yourself to be put in harm’s way all in all. You should check out Armstrong & Surin in Ottawa if you want to hire a top notch Criminal defense lawyer.

How to Buy a Piece of Jewellery That Reflects Your Personality

Different people wear jewellery for different reasons. There are some folk out there who want to buy a lot of jewellery because they want the world to know that they can afford to wear them. To some people, it’s just a status symbol and they don’t really attach any other personal value to it. Likewise, there are some people who just want to wear jewellery that looks pretty because, at the end of the day, it’s an accessory. And then there are some of us who don’t leave home without a piece of jewellery that carries a lot of personal significance.

There isn’t any right or wrong reason for buying jewellery, in truth. However, if you can find a piece of jewellery that represents something you believe in or better yet, something that inspires you, then that’s probably the best. On this page, we’ll talk about some things you can keep in mind while looking for a piece of jewellery that’s very close to you. You can check out Muru Jewellery to see some designer jewellery pieces with meaning attached to them.

If you love someone and want them to carry something that reminds them of you and your affection towards them, then a designer jewellery piece that represents the bond you have with your loved one is just about the sweetest gift you can give them. Even if you’re looking for a piece of jewellery for yourself, you can pick out something that you feel reflects your aim in life. Jewellery has this way of making you feel empowered, you know.

Maybe you didn’t have any plans on buying jewellery but then you come across a piece that’s been created with a story behind it. If you find that story inspiring then you have reasons to own that piece.

Importance of Ant Removal That You Should Know About

Although there is no denying that ants look harmless for the large part, but the issue becomes prominent when they start finding their way everywhere they can find their way in. Now the issue here is that if you have things that are sweet in nature, or just any food, the ants will be a risk to it. So, keeping that in mind, the removal of ants is something that happens to be a lot more important for a lot of people.

Now getting rid of ants is not something that happens to be extremely difficult. As a matter of fact, it is one of the easiest ways of dealing with ant situations. You can easily control – ants, wasps, cockroaches if you know what you are doing.

The thing that we are going to be discuss here is the importance. Considering how many people completely miss out on.

Ants Can Be Annoying

Simply put, ants are creatures that can be annoying for a lot of reasons, Imagine you are just going to bed, only to realize that for some reason, there is an army of ants just moving onto your bed from somewhere. I dealt with this issue fairly recently, and it was not a good one. So, make sure that you avoid it at all costs in order to have the right experience. Because it really is important.

Keep Everything Clean

Okay, if you have never dealt with a surplus of ants before, you are lucky to have never experienced that. The thing that you must know about ants is that they can make your overall living experience a lot worse by just being literally everywhere you can think about. In a situation like that, getting rid of ants is the right thing to go about.

How Ergonomic Chairs Can Help You as You Grow Older

The fact of the matter is that as you get on in years, certain things are going to end up becoming a little more important to you all in all. Paying attention to the manner in which such things are going to impact your life will be important since you don’t want to end up being dependent on anyone in your old age, and dependence is the very thing that causes so many senior citizens to feel very depressed indeed about the direction in which their life is currently headed.

The important thing to remember here is that as long as you have done a thing or two to help yourself keep your body strong, you won’t have that much to worry about at least not for a few more years. This is because of the fact that you would be able to prevent damage from occurring. Our backs tend to suffer the most as we grow older, and the reason for this is that we use our backs a lot more than we should. We place quite a bit of strain on them, and over time this strain ends up posing problems for you that are simply not going to be all that avoidable if you think about it.

By using an ergonomic chair instead of a regular one, you can prevent a lot of this strain from occurring in the first place. If you want to learn more about it visit amazinginteriordesign.com, but the basic crux of this matter is that a great deal of strain is placed on our backs because of our posture, and ergonomic chairs are great for preventing bad posture and encouraging good posture instead so you can imagine how good they are for you in your old age.

Why Vehicle Related Attorneys Are Different

When you have recently suffered from some kind of an accident that you feel was not your fault and should therefore result in you being able to get some kind of compensation that would not exactly make up for what happened to you but would at the very least allow you to enjoy your life a bit more to the point where being in an accident is not going to end up being the single most important thing that ever happened to you all in all.

The thing is, if you have been in an accident, the type of vehicle that you are driving is going to matter. If you were driving a car, your attorney is probably going to end up being a little different from one that you might end up hiring if you had been riding a motorcycle en route to wherever it is that you felt like you needed to rush to at such a great speed all in all. If you were riding a motorcycle, then hiring a motorcycle accident attorney in Nashville would be the best thing for you all things considered because of the fact that without a good quality attorney you are probably not going to be able to find the restitution that you have been searching for.

You see, the law goes into a lot of detail about stuff like this, and this sort of detail is why taking such things seriously is so important. If you don’t pay attention to the vast amount of detail in the law, then chances are that you are probably not going to be able to do much else in your life all in all. You should be more careful about such things and try to make the right decision.

How to Dry Big Batches of Laundry Quickly

If you want to be able to wash a lot of clothes all at once, one thing that you will certainly have to focus on is trying to make it so that the laundry that you are attempting to do is done in the quickest way possible. If you fail to look into this sort of thing, there is a very good chance that doing the laundry is just going to end up taking far too much time all in all, and you won’t be left with all that many options in terms of trying to make it so that the laundry is done on time.

Once the laundry has been done, you will need to focus on drying it quite a bit as well, and the good thing about drying your laundry is that if you manage to do so quickly and efficiently you can be done with it and move on to the next task that you might need to deal with all in all. You might not want to use a dryer because of the fact that such a thing could potentially end up doing your laundry a bit of damage over an extended period of time, so you need to find ways to quickly air dry your laundry.

The best way to do so would be to use some kind of a rotary washing line. This will maximize the amount of space you have in which you would be able to hang your clothes, and it will also allow you to look into more options in terms of the level of quality that you are able to enjoy all in all. Visit https://washingwoman.co.uk to find a number of high quality clotheslines that you can use.

How to Make The Right Financial Decisions

When you are sitting on a sum of money, one thing that is definitely going to be on your mind is the question of how you are going to invest this money. There are a lot of people that can help you on this matter. A fiduciary will be able to help you out quite a bit using his or her expertise on the matter and give you a rundown of the various places in which you would be able to invest your money all in all. These investments are probably going to pay you back more than you would have ever realized, but only if you are willing to put the right amount of effort into them all in all.

You can get more information available here, but the fact of the matter is that financial decisions need to be made after taking into account every single piece of information that is available to you, which means that you will have to consult a wider variety of people. You should ask your friends and family as well. This might sound odd to you because of the fact that friends and family are often not all that well verse in financial aspects of the world, but they can often help you to think outside the box.

If you really want to think outside the box, why don’t you get a psychic reading done in order to help yourself out a little bit? Psychic readings are not exactly scientific, but they do have a tendency to reveal aspects of your inner thoughts that you were either unable to realize or were ignoring for some reason that has yet to become apparent to you all in all. At least give this a try just to be sure.

Upgrade Your Security

Locks are one of those devices that have been working so well that we have not changed much about them at all. At least, that is how things used to be. Now, traditional mechanical locks are slowly beginning to lose their value ever since more modern locking options have become available to us. The biggest downside of traditional locks is that everyone knows how they work. With a bit of practice, the wrong person can pick a mechanical lock open rather easily. This is why it is important for us to assess our locks and decide whether or not it is time for an upgrade.

Modern locks come in multiple flavours, but we can differentiate between them based on whether they are electronic or not. Electronic lock systems are designed to offer an advanced level of security. They are often integrated with a computer system and can be opened with PINs, NFC chips, or magnetic cards. Electronic locks are more expensive when compared to regular ones, but they also offer much more security. Typically, these kind of locks are used in commercial sites, but there are also models available for residential usage.

Modern mechanical locks are more affordable. While they are not as safe as their electronic counterparts, they are a much better option than older locks. These locks will have a more complicated internal mechanism to make picking them open difficult. They are also made with stronger materials so that they cannot be damaged or broken easily.

If you feel that your locks need to be upgraded, you should start looking for a capable Springfield MO locksmith. An experienced locksmith will be able to guide you in what kind of locks should you pick and they can also help you with installation. ASAP Lockout Service is known for its superior services.

Regretting That Tattoo?

It is human nature to become fond of and get over things. We go through all kinds of phases when we’re particularly fond of something. There are things that impact our lives in one way or the other. Some people like to have a document of their lives on their bodies in the shape of tattoos. People get tattoos of the name of their girlfriends or wives. They also get tattoos of their pet animals and almost anything that you can imagine.

The Regret

If the tattoo is the result of a phase that has now washed over the person, they will definitely be annoyed by the tattoo on their body. Some people want to remove that name after they’ve broken up with that girlfriend/boyfriend. It’s all fair though. But the removal process is not as simple as the one that resulted in the tattoo. It’s kind of long and requires a lot of sessions with your tattoo removers.

Some Facts

Most removals are done by laser machines. This is the best way but there is a healing time afterwards. No matter what removal process you uptake, it will be long and also painful. The best way to do it is by laser.

How Does Laser Work?

Laser is a very fast and shooting pulsing light beams that are directed to the tattoo area. This laser light is absorbed by the ink of the tattoo which result in the ink breaking off and getting absorbed into the skin. The skin then releases pigments that dissolve them in the blood stream so that they can be flushed out of the body. There are many people who offer tattoo removal Las Vegas services but you should only go to the trusted ones and those whose machines are clinically approved.

The Benefits of an Electric Lawnmower

Electric lawnmowers are slowly taking over and for all the right reason. They are super convenient, and the best part is that with them, you do not have to worry about spending a lot of time mowing the lawns either. You can just turn them on, and get the job done.

Now the good thing is that most of the lawnmowers in the market are battery powered. So, the entire experience becomes all the better. If you are still not convinced as to why you should invest in an electric lawnmower, that is what we are going to be looking at in this article.

Let’s not digress any further, and have a look, shall we?

Time-Saving

A really important factor that helps a lot in time-saving is the fact that with electric lawnmowers, you do not have work really hard to mow the lawn. The process does not take as long as you might think and in no time, you are done with it as well. Just make sure you are buying a mower that is powerful enough and you would be good to go. Otherwise, you might end up with a weaker option, which will not be as convenient.

Even Mowing

I will be honest ere, as someone who is a professional at everything, uneven mowing is not something I like. I am sure many people can relate to that as uneven mowing just looks awful and out of place. With that said, if you are really looking forward to having a good experience, make sure that you buy an electrical mower because that will make the whole job so much easier, and you will always get the best possible results that you could want.

How to Cook For Multiple People Easily

If you are the sole cooker in a home full of people, you will probably focus quite a bit on making meals that everyone would be able to enjoy. Cooking for a large number of people is definitely not at all as easy as a lot of people think it is, and the fact of the matter is that if you aren’t careful about the cooking process you might just end up ruining all of the food which is going to be a problem because of the fact that you will not be able to make more food in time.

If we are talking about cooking for people that are numerous and are spread all across your home, timing is everything. You need to get the food ready on time so that it would end up in everybody’s stomachs right when they are hungry rather than before or after. You should think about how you are going to cut cooking times down by a large margin so that no one has to stay hungry for long and would end up getting dinner at a reasonable time.

This is, of course, easier said than done. Sometimes if you have a food that you are cooking, it will just take a little longer for you to cook it than everyone would like, and this is usually going to be something that people will just need to deal with since there is pretty much no way to escape it all in all. You should try to cut down cooking times by buying Japanese knives. These knives are known for being extremely precise. You should visit the home of Japanese knife to find one that is to your liking, one that will help you cook for everyone.

Why You Need to Get a Trading Journal to Be Profitable?

Finding high probability trading setups in the current dynamic environment can be quite difficult for someone with no prior experience in the forex field. Becoming a consistently profitable trader is not just dependent upon the magnitude of your financial investment, but it is also directly linked with the level of dedication you are willing to show. Top athletes have a journal to track their endurance and muscular strength. Even experienced school teachers have a journal to track the course outline and syllabus completion of their students. The same goes for successful traders, as they maintain a trading log that keeps them updated about their current financial status whether they are entering a trade or exiting it.

Making small investment mistakes on a long term basis can jeopardize your trading account, and make it susceptible to getting completely dissolved due to excessive competition in the market. Many beginner traders make the mistake of not keeping a diary, and this makes them incapable of pinpointing their financial weakness. In a goal-oriented endeavor you need to try your best to avoid taking any chances based on luck, and only purchase stocks based on the past readings.

The transaction history provided by a licensed broker would only contain the entries of your each trade, and it would not have any explanation about your main concerns of exiting and entering a trade. Edgewonk is undoubtedly the best trading journal out there in the market, and you can get honest reviews about it on the website of Foxy Trades now. Many times your gut feeling might tell you about the potential financial loss that you may face after investing in particular shares, and having a journal allows to do a post-mortem of the entire investment plan.