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If the accounts aren't holding cash in them (or minimal cash), then there's a good chance their immaterial and outside the scope of the audit. Remember the auditors are not there to audit account sign ups and whether the accounts are legit. They are there to give reasonable assurance that the financial statements are free of material misstatement. Doesn't sound like anything here is material, more compliance/consumer protection related...
We received an email last week that the external auditor and the SOX service provider at a company were issued a cease and desist order somewhere for calling things SDs vs MWs and making management decisions. They didnt say who but i wondered if it had to do with Wells.
Oooh! Interesting!!!