Explore BrainMass

FDIC Investigation/Impropriety

I was employed as a certified public accountant (CPA) for a regional accounting firm that specialized in audits of financial institutions and had many local clients. My responsibilities included supervising staff, collecting evidence to support financial statement assertions, and compiling work papers for managers and partners to review. During the audit of a publicly traded bank, I discovered that senior bank executives were under investigation by the FDIC for removing funds from the bank. They were also believed to be using bank funds to pay corporate credit card bills for gas and spouses' expenses. The last allegation noted that the executives were issuing loans to relatives without proper collateral.

After reviewing the work papers, I found two checks made payable to one executive of the bank that were selected during a cash count from two tellers. There was no indication based on our sampling that expenses were being paid for spouses. My audit manager and the chief financial officer (CFO) of my firm were aware of these problems.

After the fieldwork for the audit was completed, I was called into the CEO's office. The CEO and the chief operating officer (COO) stated that the FDIC examiners wanted to interview the audit manager, two staff accountants, and me. The CEO then asked the following question: "If you were asked by the FDIC about a check or checks made payable to bank executives, how would you answer?" I told them that I would answer the FDIC examiners by stating that, during our audit, we made copies of two checks made payable to an executive of the bank for $8,000 each

The COO stated that during his review of the audit work papers he had not found any copies of checks made payable to executives. He also stated that a better response to the question regarding the checks would be, "I was not aware of reviewing any checks specifically made payable to the executive in question. The COO then said that the examiners would be in the following day to speak with the audit staff. I was dismissed from the meeting.

Neither the CEO nor the COO asked me if the suggested "better" response was the response I would give, and I did not volunteer the information. During the interview, the FDIC investigators never asked me whether I knew about the checks. Should I have volunteered this information?


1. What would you have done? Volunteered the information or stayed silent? Explain your decision
2. Was anything unethical going on in this case? Explain
3. Describe the "ethics" of the officers of the firm in this case
4. What, if anything, should the officers have done, and why?
5. What lessons, if any, can you take from this case, as an employee working under company officials who have more power than you do?

Solution Preview

1. The information should have been volunteered. Although the FDIC investigators did not specifically ask about the checks, there are obvious improprieties occurring at the bank that should be dealt with. It is difficult to 'blow the whistle' considering that losing one's job is a likely outcome. However, the purpose of the FDIC is to stand as a second line of defense to insure the cash of the general public and, as such, the bank remains the first line. In this situation, you could claim federal whistle blower protection status and eliminate the possibility of going to jail later (although you did not directly commit fraud, you would be found guilty by association if tried because you ...

Solution Summary

A CPA auditing a bank during an FDIC review uncovers impropriety and is torn between blowing the whistle and remaining silebt.