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The Regents - University of California | Office of The President

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and consented to have its audit opinion attached to public documents. <strong>The</strong>se red<br />

flags included the following:<br />

! Andersen deemed WorldCom to be a maximum risk client with overly<br />

aggressive revenue and earnings targets and a history <strong>of</strong><br />

misapplication <strong>of</strong> GAAP principles. According to the First Interim<br />

Report <strong>of</strong> Dick Thornburgh, Bankruptcy Court Examiner dated<br />

November 4, 2002, pages 50-51:<br />

In planning the 1999 audit <strong>of</strong> the Company, Arthur<br />

Andersen personnel noted in workpapers that (1)<br />

historical purchase accounting adjustments represented a<br />

significant portion <strong>of</strong> the 1999 budgeted income; (2)<br />

WorldCom had misapplied GAAP with respect to<br />

certain investments; and (3) due to WorldCom’s use <strong>of</strong><br />

multiple billing systems that require significant human<br />

intervention, there was a high degree <strong>of</strong> risk in the<br />

Company’s billing and collection areas.<br />

Moreover, a memo in the 1999 Arthur Andersen<br />

workpapers states that, “in the past, we have noted<br />

situations where management has taken aggressive<br />

accounting positions, particularly in the area <strong>of</strong><br />

purchasing accounting.” In addition, in its meetings<br />

with WorldCom’s Audit Committee for the 1999 audit,<br />

Arthur Andersen expressed that the items in<br />

WorldCom’s financial statements that represented<br />

particularly sensitive accounting estimates were:<br />

Purchase Accounting, Evaluation <strong>of</strong> Asset Impairment,<br />

Line Cost Accrual, Tax Accrual; Litigation, and<br />

Depreciation Reserves. (Emphasis added.)<br />

<strong>The</strong> report also notes that Andersen, in rating the overall risk<br />

assessment <strong>of</strong> WorldCom and its management team in connection<br />

with the planning <strong>of</strong> its audits for the years ended December 31,<br />

1999 through 2001 found significant risk for “accounting and<br />

financial reporting risk” and “overly aggressive revenue or<br />

earnings targets.”<br />

! Andersen knew that financial fraud by accounting for costs as capital<br />

investments rather than expenses was not a new scheme. <strong>The</strong>re have<br />

been significant examples <strong>of</strong> companies which have improperly<br />

60<br />

COMPLAINT

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