Texas State Board of Public Accountancy

KPMG performed an internal investigation beginning in the Fall of 2018 that uncovered wide-spread sharing of internally administered training exam materials across the nation and subsequently reported their findings to the SEC. The June 17, 2019 Order issued by the Securities and Exchange Commission contained findings of KPMG's conduct related to test sharing but did not include any finding specific to my conduct. In the Fall of 2020, The Texas State Board of Public Accountancy instituted a matter to investigate the specific involvement of individuals that were licensed by the State of Texas and alleged that my misconduct related to internally-administered Continuing Professional Education violates Board rules regarding integrity and objectivity and compliance with Continuing Professional Education requirements. My involvement timeline was from when I started employment with the firm in the Fall of 2015 until Fall of 2018 when KPMG began their investigation and amended their Code of Conduct to explicitly prohibit collaborating on internally administered training courses.

Order

Letter of Reprimand

In the response letter to the State Board, I noted the four test sharing instances I had previously engaged in and self-reported, which included the instances that were not eligible for continuing professional education (CPE) credit as well. I also confirmed in the response letter that I never submitted any courses for CPE credit to the Board where I engaged in this behavior nor was that ever my intention to submit shared exams for CPE credit. It also discusses the circumstances leading to the test sharing, including the open book nature of the exams, KPMG's promotion of a collaborative culture and at the time, not explicitly prohibiting discussing the internal exam material with other colleagues, which changed in the Fall of 2018 as a result of the investigation. Additionally, as noted in the response letter, there are dozens of potential questions on KPMG's internally administered tests and as such, there were some overlapping questions, but the tests were not in any way identical to the tests I ultimately took. I performed my own work and consulted the materials received only as an additional resource to check my work once I completed the test. Since the Fall of 2018 when I self-reported, I have not engaged nor will I ever engage in such behavior again. Additionally, all KPMG professionals have completed extensive ethics courses as a result of the SEC settlement. Once the Texas State Board of Public Accountancy completed their review of my individual facts and circumstances, I received a written reprimand for a violation of Board Rules Sections 501.73 and 523.114 as well as the Public Accountancy Act Section 901.502(6). I did not receive a fine by the Board nor did I receive any suspension of my license based on my limited involvement. I signed an Agreed Consent Order, which included a ratification that the Agreed Consent Order (ACO) is a complete resolution of the issues in the matter and that there will be no further disciplinary action beyond the reprimand. Additionally, as noted above, the SEC's Order contained findings of KPMG's conduct related to test sharing but did not include any finding specific to my conduct. My intention was never to engage in any activity that called into question my integrity or ethical standards, nonetheless, I recognize that engaging in test sharing of any kind did in fact do that and constituted a lapse in judgment early in my career for which I am deeply remorseful.