auditing questionnaire

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standard accounting services sas 70

I've been in IT for more than 15 years and endured more than 2 dozen SAS-70 audits. It's easy to find information about SAS-70 but what I'm about to share are the unwritten rules that no one is going to tell you about how to pass a SAS-70 audit. Whether you've recently been handed SAS-70 and told to “make sure you pass” or you're a SAS-70 veteran, this four part series will give you the information and skills you need to ensure that your SAS-70 audits are virtually painless. OK, a SAS-70 is never painless but it's a lot easier to get through it if you have the right information.

Part one of the series starts with SAS-70 basics. If you're struggling with the fundamentals of a SAS-70 and need some real world perspective, this is a great place to start. Part two delves into what you need to be doing to prepare. The preparation takes longer than the audit but is well worth the time you invest. Next, part three explores what types of things auditors look for during an audit. Hint: they're not just looking at paper. Lastly, part four will provide tips on how to appropriately interact with auditors. How you interact with the auditors is both an art and a science.

I remember being told for the first time that I was going to be responsible for enforcing SAS-70 controls within my organization. “SAS-70?” I asked. “What is that?” I found out quickly that the Statement on Auditing Standards (SAS) No. 70 is one of the most widely used auditing standards enforced by the American Institute of Certified Public Accountants. Even though a SAS-70 is an American accounting standard, the heightened awareness around risk management and internal controls is global. Many organizations have expanded their operations to global market spaces. As a result, SAS-70 has become an increasingly popular audit standard in many countries. So what is it and what is the purpose?

I was asking myself those questions as I sat in the darkened conference room on the first floor of our regional headquarters. The door opened and two individuals in black suits and dark glasses entered. One of them turned on a very bright spotlight directed at my face which made it difficult to see. The first gentleman sat down and placed a manila folder on the table in front of him. Slowly, he slid it over.

“You've never been through a SAS-70 before?” he asked in a low voice. Too afraid to speak I nodded my head no. The man looked at his colleague and they both laughed in a very contrived manner. “You tell us what we want to know and no one will get hurt.”

“Dawn?” Our SAS-70 coordinator, John, shook me out of my day-dream – actually it was more like a nightmare of what I pictured the SAS-70 audit would be like. “I'd like you to meet the auditors. This is Megan and Melissa.” I turned to find two very pretty, well manicured and efficient looking young women with briefcases standing in the doorway.

“You're the auditors?” I asked as I shook their hands. They both nodded, smiled brightly and sat down on the other side of the table. Flabbergasted, I sat back down to face them as they neatly unpacked their briefcases, set up their laptops and obtained the tools they were going to need for the question and answer session.

And thus began my SAS-70 journey – a journey where I kept a watchful eye, took copious notes and made numerous mistakes that I hope to share in an effort to ensure that you don't make those same mistakes. The first thing I learned was that understanding the basics of what a SAS-70 was would give me almost 50% of the skills I needed to ensure that our company passed its SAS-70 audit.

What is the actual definition of a SAS-70 audit? The Statement of Auditing Standards website http://www.sas-70.us defines it as “A set of guidelines which guides the service organizations on how to disclose their control processes, activities and objectives to their customer's auditors and their customers in a uniform and standardized reporting format.” My definition? A cross between an IRS audit and a proctology exam. If you're a subject matter expert, SAS-70 coordinator or business owner, plan to sit in a room for several hours with consultants freshly out of college picking apart every aspect of your business practices and questioning their validity. Even worse, if the auditors find *any* tiny part of your business practices that do not conform to their rigid code, they can fail you.

Why would a company want a SAS-70 audit? The purpose of a SAS-70 audit is to give service providers the opportunity to disclose their internal processes and controls to an independent auditor so the auditor can give their honest opinion on how effective and adequate the controls are. The findings of a SAS-70 audit are used by financial auditors to prepare reports on the financial viability of the service organization. These financial statements can be provided to companies using the services of the service provider. Bottom line, the audit is really nothing more than the objective opinion of an auditor and not subject to any benchmarked industry standards. While SAS-70 forces many companies to look at their processes, procedures and control points and improve those processes, SAS-70 is a buzz word. Many far-removed individuals get a warm and fuzzy feeling upon hearing that a company is “SAS-70 compliant.”

What are the components SAS-70 audit? A SAS-70 audit revolves around a list of what are known as “control objectives.” Control objectives are nothing more than statements about how a process or procedure is executed. An example might be, “User acceptance testing is conducted by the client. Clients are then asked to sign the User Acceptance Sign-off Form to ensure that the testing was complete and return it to their designated account manager.” In order to test the effectiveness of this control, the auditor might ask for the signed user acceptance sign-off forms for certain dates for certain clients.

Who is subject to a SAS-70 audit? The growing popularity of businesses outsourcing non-core competencies has really forced many companies to engage in a SAS-70 audit. Ann Bednarz in her Network World Fusion article entitled “Offsite security complicates compliance” states that service providers that perform the role of an outsourced service like benefits, HR or payroll are subject to a SAS-70 audit. The key to knowing whether or not a company is subject to an audit is understanding where the control lies. If a company uses an outsourcer for certain types of transactions but is still responsible for the processes, procedures and controls, then the outsourcer would not necessarily be subject to an audit. If there is any question as to whether or not your company would be subject to an audit, it is best to obtain outside counsel from independent auditing firms.

Who performs a SAS-70 audit? Since SAS-70 reporting standards are stringent and must be followed to an exacting standard, only independent certified public accountant (CPA) or firms of CPAs are allowed under the US regulations to conduct a SAS-70 audit. One thing to keep in mind, many independent audit firms hire individuals that are not CPAs to conduct SAS-70 audits. Most of the auditors with which I have interacted have been young, driven and sharp. Usually, these individuals are sent to a training class which lasts anywhere from 4-6 weeks and then they are placed in the field with a more senior auditor to observe before going off on their own. Many of them lack true practical experience and have difficulty applying their “book knowledge” to real life scenarios. Don't get me wrong – there are plenty of experienced professionals out there but learning how to differentiate between them and the ones that are green and fresh out of college will help you understand how to appropriately interact with them.

Where is a SAS-70 audit conducted? Every SAS-70 audit I've ever been involved in has been conducted onsite. That means that auditors will be coming to your place of business to conduct the audit. Concerned? Don't be. As long as you have someone with the auditors at all times and a work location designated, this really isn't a cause for concern.

Is the audit process standardized? While auditing practices and standards can vary from state to state, the American Institute of Certified Public Accountants (AICPA) has established strict guidelines with respect to planning, execution and supervision of auditing procedures. Always remember that the auditors are not auditing against a library of “best practices.”

What is the difference between a Type I and a Type II audit? Type I audits capture descriptions of controls and processes at a point and time. Type II audits are the descriptions of the controls and processes which are tested for effectiveness. Most companies opt for a Type II audit due to the stringent amount of control testing that is said to be employed by the auditors. Keep in mind, though, that the tests of effectiveness are not scenarios that an auditor dreams up and then executes. Tests of effectiveness are nothing more than showing that you do what you say you do and you can prove it.

How is a SAS-70 audit conducted? The best possible scenario for an audit is to make one individual the point person for the auditors. This person would be responsible for coordinating dates and times of the auditors' visit, gathering any documentation needed ahead of time and setting up a complete agenda. The best SAS-70 agendas I've seen have been agendas that slot 1-2 hour meetings for each control objective. Invited to those meetings are the senior leader of the department and any subject matter experts that can talk to the controls. The SAS-70 coordinator should reserve a private conference room or area which will be free from disturbances for the auditors to work. For each of the designated meeting times, the appropriate individuals should come to the designated area on time with a copy of the controls to be reviewed. As the audit begins, there is a brief question and answer session as the auditor reviews the controls. In Type II audits, documentation to support the use of the controls is required and sometimes auditors may also ask to observe the control being used in an actual situation.

How often is a SAS-70 audit conducted and how long does it take? Depending on the number of controls, companies can choose to do audits every six or twelve months (twelve being the minimum acceptable standard). Some companies choose to do an interim and a final to ensure they are prepared. Audits usually last anywhere from 2-5 days depending on the complexity and scope of the audit. It's also plausible that the auditors may request additional meetings or documentation as follow up even after the on-site audit is complete.

What are the inputs and outputs of a SAS-70 Type II audit? At the conclusion of a SAS-70 audit, a Service Audit Report is issued. The report contains a list of the controls and the auditor's opinion on the effectiveness and adequacy of the controls in use. For Type II audits, the auditor must include detailed information on how the controls were tested. The report will be issued with either a qualified or unqualified opinion or may contain exceptions. An unqualified opinion is issued when the audit examination was adequate in scope and the auditors have observed that the controls are being followed as stated. A qualified opinion is issued when the auditor observes significant limitations existed, such as an inability to prove that a process or control is being consistently followed. An exception is noted when a process or control seems to be followed a majority of the time but the service organization is not able to produce proof of a specific item requested by the auditors. Exceptions are OK and quite frequent. We're all human and it's conceivable that not all individuals will follow processes and procedures 100% of the time even if they have good intentions. A qualified opinion is NOT OK. When a qualified opinion is issued, it calls into question a company's business practices. In addition, it can also be cumbersome and time consuming. One of the large corporations I worked for once received a qualified opinion. The result was more than 50 hours worth of conference calls and conversations with corporate auditors, internal auditors and the independent auditors. On top of all that, corporate sent their own auditors out to conduct yet another audit on top of the SAS-70 audit we'd just gone through. Take my word for it, conducting your own pre-audit is never a bad idea. It will take a lot less time than if you have to endure having to explain to company executives and customers why you received a qualified opinion.

When a company is deemed SAS-70 compliant, does it mean that their controls and processes have been audited against a set of best practices? SAS-70 compliance does not mean that a company has been audited against a set of best practices; instead, it indicates that a company has a set of controls and they follow those controls. In my personal experience, I've seen SAS-70 controls that were absolutely the worst business practices I've ever witnessed; however, because they were documented and the controls were being followed, the company passed the SAS-70 audit with flying colors. The lesson here is that a process is better than no process.

Now that you know the basics, read part two of my SAS-70 series to know what you need to do to prepare.

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compliance accounting

Introduction

In a time where currency is as useless as it was during the infamous hundred-days of the FDR Administration of the post Depression era, the world again has found itself asking the million dollar question of whom or what governs the accounting profession. The new millennium has seen its share of financial misfortune and scandal throughout the past decade from Main Street all the way to the White House. As the United States welcomes a new administration such questions require more attention than ever.

Governing Bodies in the Accounting Profession

One of the most recognized authoritative bodies of the accounting profession is the Financial Accounting Standards Board or FASB. The FASB is centered on the production and publication of accounting standards and policies throughout the accounting profession. There are several various pronouncements declared by the Financial Accounting Standards Board (FindMyBestCPA.com, 2007). These pronouncements include the following nine brands of financial statements.

  1. Statements of Financial Accounting Standards (FAS).
  2. Statements of Financial Accounting Concepts (SFAC).
  3. Statements of Interpretations (FIN).
  4. Technical Bulletins (FTB).
  5. Implementation Guides.
  6. Invitations to Comment.
  7. Research Reports.
  8. Discussion Memorandums.
  9. Special Reports (FindMyBestCPA.com, 2007).

These decrees have been designated for the most fundamental procedures and topics within the accounting profession. According to the Federal Accounting Standards Advisory Board pronouncements regarding accounting changes include:

1. FAS 3, Reporting Accounting Changes in Interim Financial Statements.

2. FAS 73, Reporting a Change in Accounting for Railroad Track Structures.

3. FAS 111, Rescission of FASB Statement No. 32 and Technical Corrections.

4. FIN 1, Accounting Changes Related to the Cost of Inventory.

5. FIN 20, Reporting Accounting Changes under AICPA Statements of Position (FindMyBestCPA.com, 2007).

As shown through this extensive list, there are several sub-topics listed throughout these pronouncements.

Balance sheet classification also includes Generally Accepted Accounting Principles or GAAP pronouncements regarding various topics in the accounting profession (Investopedia ULC, 2009). The Statements of Financial Accounting Standards also included:

  1. FAS 6 – Classification of Short-Term Obligations Expected to Be Refinanced
  2. FAS 43 – Accounting for Compensated Absences
  3. FAS 78, Classification of Obligations That Are Callable by the Creditor (Investopedia ULC, 2009).


Interpretations on this topic include:

  1. FIN 8 – Classification of a Short-Term Obligation Repaid Prior to Being Replaced by a Long-Term Security
  2. FIN 39 – Offsetting of Amounts Related to Certain Contracts (Investopedia ULC, 2009).

Capitalization of interest costs is yet another area containing both FASB Statements of Financial Accounting Standards and Interpretation (Federal Accounting Standards Advisory Board, 2009). Statements of Financial Accounting Standards regarding the capitalization of Interest costs are:

  1. FAS 34 – Capitalization of Interest Cost.
  2. FAS 42 – Determining Materiality for Capitalization of Interest Cost.
  3. FAS 58 – Capitalization of Interest Cost in Financial Statements That Include Investments Accounted for by the Equity Method.
  4. FAS 62 – Capitalization of Interest Cost in Situations Involving Certain Tax-Exempt Borrowings and Certain Gifts and Grants (Federal Accounting Standards Advisory Board, 2009).

The Interpretation regarding this topic is FIN 33, Applying FASB Statement No. 34 to Oil and Gas Producing Operations Accounted for by the Full Cost Method (Federal Accounting Standards Advisory Board, 2009).

Another accounting principle bearing GAAP pronouncements issued by FASB regards accounting for leases (Federal Accounting Standards Advisory Board, 2009). Statements of Financial Accounting Standards concerning this topic include:

  1. FAS 13 – Accounting for Leases.
  2. FAS 23 – Inception of the Lease.
  3. FAS 28 – Accounting for Sales with Leasebacks.
  4. FAS 91 – Accounting for Nonrefundable Fees and Costs Associated with Originating or Acquiring Loans and Initial Direct Costs of Leases (Federal Accounting Standards Advisory Board, 2009).

FASB Interpretations for this topic, include:

  1. FIN 19 – Lessee Guarantee of the Residual Value of Leased Property.
  2. FIN 21- Accounting for Leases in a Business Combination.
  3. FIN 24 – Leases Involving Only Part of a Building (Federal Accounting Standards Advisory Board, 2009).

The Sarbanes-Oxley Act, 2002

In 2002 President George W. Bush signed the Sarbanes-Oxley Act. This piece of legislation was signed in response to the infamous Enron and WorldCom financial scandals. The purpose of this act is to protect shareholders and general consumers alike from accounting errors and fraudulent practices commonly associated with these two now extinct corporate entities. The Sarbanes-Oxley Act is administered by the Securities and Exchange Commission (SEC). The SEC is charged with setting deadlines for compliance and the publication of rules of standard requirements. The act essentially defines how financial records are to be stored by businesses and the appropriate length of time in which to store them which according to this legislation is no less than five years. Business owners and executives who fail to comply with this act are subject to fines, imprisonment and in extreme cases both. As such, IT technicians are constantly searching for new ways to effectively meet the demands of the legislation (FindMyBestCPA.com, 2007).

The following three sections of Sarbanes-Oxley contain rules that directly pertain to the management of electronic records. The first rule addresses the destruction, alteration, and/or falsification of records.

“Whoever knowingly alters, destroys, mutilates, conceals, covers up, falsifies, or makes a false entry in any record, document, or tangible object with the intent to impede, obstruct, or influence the investigation or proper administration of any matter within the jurisdiction of any department or agency of the United States or any case filed under title 11, or in relation to or contemplation of any such matter or case, shall be fined under this title, imprisoned not more than 20 years, or both.” – Sec. 802(a) (United States Congress, 2002).

The second rule mentioned in this act regarding financial records defines the retention period for records storage.

“Any accountant who conducts an audit of an issuer of securities to which section 10A(a) of the Securities Exchange Act of 1934 (15 U.S.C 78j-1(a)) applies, shall maintain all audit or review work papers for a period of 5 years from the end of the fiscal period in which the audit or review was concluded.” – Sec. 802(a)(1) (United States Congress, 2002).

Lastly, the third rule defines what type of business records should be stored. This includes all business records and communications as well as electronic communications.

“The Securities and Exchange Commission shall promulgate, within 180 days, such rules and regulations, as are reasonably necessary, relating to the retention of relevant records such as work papers, documents that form the basis of an audit or review, memoranda, correspondence, communications, other documents, and records (including electronic records) which are created, sent, or received in connection with an audit or review and contain conclusions, opinions, analyses, or financial data relating to such an audit or review.” – Sec. 802(a)(2) (United States Congress, 2002).

Conclusion

Keeping accurate, up-to-date financial records is essential for all businesses, both big and small. If we have learned anything from the WorldCom and Enron scandals it is that you can never be too careful or careless for that matter. If anything positive came out of the Bush Administration it would have to be the Sarbanes-Oxley Act of 2002. Without such legislative measures and governance in our nation's financial centers and corporations, corruption, greed and ignorance would consume our economy, leaving nothing sustainable to build upon. In retrospect, Sarbanes-Oxley may have proven to be too little too late as our nation and the rest of the world takes on one of the most financially trying times in history.

References

Federal Accounting Standards Advisory Board. (2009). Generally Accepted Accounting Principles. Retrieved February 22, 2009, from fasab.gov: http://www.fasab.gov/accepted.html FindMyBestCPA.com. (2007). Tax & Accounting Articles – Governing Bodies and Regulations .Retrieved February 22, 2009, from findmybestcpa.com:

http://www.findmybestcpa.com/Accinfo/FASB/154.html

Investopedia ULC. (2009). Generally Accepted Accounting Principles – GAAP. Retrieved February 22, 2009, from investopedia.com: http://www.investopedia.com/terms/g/gaap.asp

United States Congress. (2002, January 23). Sarbanes-Oxley Act of 2002. Retrieved February 22,

2002, from findlaw.com: http://fl1.findlaw.com/news.findlaw.com/hdocs/docs/gwbush/sarbanesoxley072302.pdf

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audit checklist

J.K.Lasser's 'Your Income Tax' series has been helping millions of taxpayers for 70 years. In fact, 2007 is the 70th year for this informative and helpful tax law guide. The reason for its popularity is the fact that J.K.Lasser's 'Your Income Tax' takes the complex IRS Tax Code and explains it in easy to understand terms. Readers do not have to be trained in accounting or the tax law to comprehend what is being written. Plus, rules and regulations are applied to real-life situations. There are, however, many other reasons for its popularity. Here are some:

It is easy to find information. If I'm interested in an itemized deduction, for instance, all I need to do is flip to the index. The index is well written, comprehensive, and easy to read. If I don't want to use the index, I can just as easily flip to the Table of Contents. Here, subject areas are broken down per chapter. It is very easy to find what I am looking for. Plus, subject areas in the Table of Contents are separated with a heavy, thick line. Nice. Each chapter contains Parts, subparts, topic subject, and page number. It is very easy to find what I am looking for.

Updates. I can be updated about current tax developments and tax law changes. In addition to being in the guide, if a tax law was still in Congress at the time the book was taken to the publisher, there will be a section describing the proposed tax law. Plus, I can receive a free e-supplement from J.K.Lasser's website. Here, there are also links to the IRS and state tax forms.

Reference Form. What is really nice about J.K.Lasser is the fact that the front of the book contains a Form 1040 with reference numbers to the applicable sections of the tax guide. How easy is that? For instance, if I am interested in 'Residential energy credits', I just look on the Form and see that section 25.20 applies. That is a very helpful and time-saving feature.

How To Use. There also is a 'How to Use' guide in the front of the book. It contains various icons located throughout the book, along with the explanations. The icons consist of Filing Tips, Planning Reminder (for tax planning), Caution (tax areas of concern to the IRS), Law Alert (what's happening in Congress tax-wise), Court Decision (key rulings by the Tax Court and other federal courts), and IRS Alerts (key rulings and announcements). These icons are found throughout the 2007 tax guide alongside the applicable subject areas. Once again, the explanations are well-presented, easy to find, and easy to understand.

Tax planning. This Guide also helps with tax planning. There is an entire two sections of subject areas that apply to different taxpayers. There's Tax Planning (gift and estate, household employment tax, military, i.e.) and Business Tax Planning. By reading this section, I can see how a tax law can help with my current and future financial picture. The section titled 'Income or Loss From Your Business or Profession' is especially informative.

Filing status. It's easy to figure out what filing status to use when preparing tax returns. The section on this is very comprehensive and well-presented.

It's easy to see the requirements and thresholds for filing different Form 1040s. By reading “Choosing Which Tax Form to File” I know what is included in a Form 1040EZ, Form 1040A, and Form 1040. I can easily see what applies to me. The information is super easy to understand.

Checklist. The checklist that breaks itemized deductions into deductible and nondeductible is especially helpful.

There is so much information in this tax guide, a short article just skims the surface. After all, J.K. Lasser 'Your Income Tax 2007' is a 800-plus page book. It covers everything a taxpayer could possibly want to gain a better comprehension of the IRS tax laws and how they apply to individual situations.

The only drawback to the J.K. Lasser 'Your Income Tax 2007' is the fact that sometimes the verbiage still is rather confusing. Upon wanting information on a tax subject, I ended up just reading what seemed like the IRS Code. The information in the Guide was not well-deciphered. I got done reading a couple of tax sections in this guide and went, “WHAT??!!” The reason for this is the fact that J.K.Lasser's tax guide is edited by attorneys.

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compliance software

Ford have been gradually squeezing more functionality into their SYNC in-car computing platform, and now they’ve joined up the dots between the Nuance speech-recognition system added earlier this year and the smartphones Ford drivers are carrying.  The new Ford SYNC AppLink – which will be first available on the 2011 model year Fiesta – will hook up to Android and BlackBerry handsets and allow for voice-control of applications updated for compliance with the company’s new APIs.  Initially, that will include Pandora, a Twitter app and a streaming radio app.

Video demos after the cut

As well as Pandora internet radio, Stitcher “smart radio” and Orangatame’s OpenBeak app for Twitter there’ll be other apps that hook into the SYNC system, and of course there’ll still be voice control over the standard in-care entertainment.  Compatible software will also be able to respond to steering wheel controls, meaning there’ll be less of a need to take your hands off the wheel.

Ford expect the official API to go public later in 2010, along with example apps and full documentation, at their SYNC Mobile Developer Network.  After the Fiesta, it’ll be rolled out to all SYNC-enabled vehicles in their range, and they also plan to add iPhone compatibility as well.

  1. Create a voice UI for your application using the in-vehicle speech recognition system.
  2. Write information to the radio head display or in-vehicle touchscreen
  3. Speak text using text-to-speech engine.
  4. Use the in-vehicle menu system to provide commands or options for your mobile application
  5. Get button presses from the radio and steering wheel controls.
  6. Receive vehicle data (speed, GPS location, fuel economy, etc.)

SYNC AppLink and the New 2011 Ford Fiesta:

Ford SYNC and Pandora:

Ford SYNC and Stitcher:

Ford SNYC and OpenBeak:

Press Release:

SYNC APPLINK TO LAUNCH ON 2011 FIESTA, MAKING FORD FIRST TO DELIVER VOICE CONTROL OF SMARTPHONE APPS

· Ford will first offer SYNC® AppLink, a downloadable software program, on the 2011 Fiesta, allowing owners to access and control AndroidTM and BlackBerry® smartphone apps with voice commands and vehicle controls

· Pandora internet radio, Stitcher “smart radio” and Orangatame’s OpenBeak are the first SYNC-enabled mobile applications

· Ford to create SYNC developer community with launch of new “Mobile Application Developer Network” (www.syncmyride.com/developer), giving developers a pathway to partner with Ford on SYNC-enabled applications

· Ford’s platform approach with SYNC is poised to harness smartphone app development and mobile web access; apps expected to be a $4 billion industry by 2012; analysts predict the mobile device to become the No. 1 source for Internet access by 2015

SAN FRANCISCO, April 20, 2010 – Customers have spoken — asking for safe, convenient access to their smartphone apps while in the vehicle – and Ford is responding by announcing the new SYNC AppLink software that will allow hands-free voice control of popular smartphone apps.

SYNC AppLink, a downloadable software upgrade, will be released for 2011 Ford Fiesta owners with the award-winning SYNC communications and infotainment system later this year, allowing drivers hands-free control of apps on their Android or BlackBerry smartphones via voice commands and vehicle controls. Ford will introduce AppLink on all SYNC-equipped vehicles next year, as well as provide interoperability with iPhone and other smartphones.
“The growth in smartphone mobile apps has been explosive, and Ford has worked hard to respond at the speed of the consumer electronics market,” said Doug VanDagens, director of Ford’s Connected Services Organization. “SYNC is the only connectivity system available that can extend that functionality into the car. AppLink will allow drivers to control some of the most popular apps through SYNC’s voice commands and steering wheel buttons, helping drivers keep their hands on the wheel and eyes on the road.”

The Android MarketTM and BlackBerry App World™ are among the leading growth markets for mobile apps. The new SYNC AppLink will seamlessly integrate apps using the vehicle’s voice and user interface controls, including buttons on the steering wheel, increasing eyes-on-the-road and hands-on-the-wheel time.

The first SYNC-enabled apps available later this year include Pandora internet radio, Stitcher “smart radio” and Orangatame’s OpenBeak app for Twitter, with additional apps on the way. Updated versions of each app, incorporating the SYNC application programming interface (API), will be available through Android Market and BlackBerry App World for customers to download.

Built-in, Beamed-in and Brought-in: The SYNC App Ecosystem
From its introduction, Ford has been building an ecosystem of available SYNC apps, continuously improving the consumer experience.
· Built-in apps, including Vehicle Health Report and 911 Assist™, are downloaded and installed directly on the in-car SYNC operating system
· SYNC apps like Traffic, Directions & Information rely on beamed-in, or “cloud-based,” information. Drivers access the Ford Service Delivery Network, a network of data centers providing turn-by-turn directions, business searches, and on-demand news, sports and weather information, through a simple voice-connection using their cell phone.
· SYNC AppLink represents the third category of the ecosystem, brought-in apps, leveraging apps installed on a user’s smartphone, such as Pandora, Stitcher and OpenBeak

Studies show mobile app development – a niche market just three years ago – is expected to blossom into a $4 billion industry by 2012. Sites serving specific mobile operating systems, such as Android and BlackBerry OS, have experienced massive growth, with analysts predicting the mobile device will become the No. 1 source for Internet access by 2015, surpassing the home computer.

Ford and SYNC will answer the consumer demand by offering the only platform available for drivers to safely control their mobile devices and applications in the car. Leveraging SYNC’s safer voice commands and steering wheel controls, drivers are able to keep their hands on the wheel and eyes on the road. “Brought-in” apps residing on a consumer’s smartphone also eliminate the need for yet another piece of hardware to be installed in the car which only serves to add cost and complexity.

Customers will be able to download SYNC-enabled mobile apps through the same app store interfaces currently used. As SYNC-enabled versions of existing apps are released into the app stores, users will be prompted to download the latest version upon connection. Also, as developers grasp the notion that the vehicle interior has opened to them, a new dimension of apps designed from the outset to maximize the unique in-car environment will follow.

Opening the door to developers
To facilitate future SYNC-enabled app development, Ford has also activated a new developer network on its SYNCmyride Web site (www.syncmyride.com/developer). Interested developers can find a link to submit innovative ideas, and sign up for the latest information and news about the SYNC application programming interface (API) and software development kit (SDK). The package will allow developers to modify existing applications and create all-new apps that can successfully interface with SYNC.

Working with trusted partners, Ford is completing beta-testing on the SDK. Once beta-testing is complete, a broader release of the development tools is planned for later this year. Initial reports have been positive, with one of Ford’s development partners creating a SYNC-enabled version of its app just three days after receiving the development tools.

“We’re very pleased by the rapid development time and positive feedback we’ve seen from our first partners,” said VanDagens. “We want to encourage all developers to visit our site and submit ideas, helping us tap into the global pool of innovation and creativity.”


Software development company Loohuis Consulting and process management consultancy OpenDawn have released a new binary analysis tool that is designed to detect Linux and BusyBox in binary firmware. The program, which is freely available for download, is intended to aid open source license compliance efforts.

Open source software licenses broadly enable redistribution of application source code, but some impose additional stipulations on derivatives. There is an entire class of reciprocal open source software licenses, sometimes called “copyleft” licenses, that require derivatives to be distributed under the same terms as the original code base. The purpose of such licenses is to ensure that third-party enhancements to the code are disclosed and made available to all members of the community.

The most popular copyleft license, the GNU General Public License (GPL), has become a powerful enabler of collaboration, but a growing number of companies fall afoul of its requirements. Bradley Kuhn, the technical director of the Software Freedom Law Center (SFLC) revealed last year that he finds an average of one new GPL violator every day. A GPL violation constitutes copyright infringement and puts the violator in a position where they risk having their license to use the software terminated. The SFLC and a handful of other organizations such as gpl-violations.org, attempt to educate companies about GPL compliance and help them conform with the requirements of the license.

In rare instances, some open source software projects have used litigation in response to persistent and uncorrected violations. For example, the open source BusyBox project—which provides a set of command-line tools and a lightweight interactive shell for mobile Linux computing environments—has been at the center of a string of GPL enforcement lawsuits targeted at mainstream consumer electronics vendors.

As licensing enforcement experts have explained in the past, compliance is not particularly burdensome—companies really just need to pay attention and do due diligence. That is one area where the new binary analysis tool could potentially be helpful. The tool is developed by Armijn Hemel and Shane Coughlan, the people behind the two consulting firms that released the software. Hemel is widely-known for his contributions to the gpl-violations.org effort.

The tool is designed to analyze binary device firmware images in order to detect software. It can extract BusyBox version and configuration data and find strings that indicate the presence of the Linux kernel. It is built around an extensible “knowledgebase” which means that it can be extended to scan for other specific pieces of software. It could be useful tool for companies that are uncertain about the contents of their firmware and want to verify whether it contains Linux or BusyBox.

Developed with funding from the Linux Foundation and the NLnet Foundation, the binary analysis tool is distributed under the permissive Apache license. It is available for download from the project's website, along with some introductory documentation and other details. The source code, which is largely written in the Python programming language, is available from the project's public Subversion repository.

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risk management

The World Food Programme feeds almost 100 million people around the world. It has a world class logistical capability but its financial risk management capacity is extremely limited. In a new paper coauthored with Benjamin Leo and Owen McCarthy, I argue that the World Food Programme must be empowered to actively manage price risk, using financial markets to feed more people in a timely manner. The United States and other significant funders can also play a significant role.

Currently, 100 percent of WFP food procurement is executed through spot markets. This exposes it to substantial commodity and transport price risk as well as significant food delivery delays. In 2008, the WFP experienced a 40-50 percent budget gap due to sharp commodity and transport price increases. The net impact was dramatically higher per capita food assistance costs and sustained levels of hunger and malnutrition in some parts of the developing world. The WFP has limited flexibility to actively manage price risks. This is due to its reactive and unpredictable revenue mobilization model (relying on emergency appeals); lack of multi-year donor contribution commitments; and restricted donor contributions (in-kind transfers or program earmarks). Unrestricted cash contributions typically account for less than 10 percent of the WFP's total budget. Our paper offers three complementary policy recommendations:

  1. The WFP and its Board should implement a targeted hedging pilot focused on chronically food-vulnerable countries, using a conservative decision making methodology. There are several risk management instruments available for WFP operations, such as physical call options, forward contracts, and futures contracts. All instruments are utilized widely for risk management purposes. Several commodity exchanges offer sufficient commodity coverage and market depth to prevent market distortion effects. Key benefits include greater financial predictability, the potential for improved delivery times; and increased local and regional trade, building upon the WFP's Purchase for Progress initiative.
  2. The United States and other rich countries should commit untied cash donations to increase WFP operational flexibility. The United States and other rich countries could instruct WFP management to utilize these cash resources specifically for the proposed hedging pilot. Also, donor contributions to the proposed World Bank Food Security Trust Fund could support WFP hedging operations. Specifically, the World Bank Trust Fund could provide a financial guarantee or modest credit line to the WFP, which would enable it to enter into commodity derivative contracts up to one year in the future. With appropriate policies in place, the practical Trust Fund impact would be very modest.
  3. The United States should utilize forward purchases for its own in-kind contributions to the WFP, increasing certainty for the WFP and for American farmers. Currently, U.S. in-kind contributions are appropriated based on monetary values instead of metric tonnage. This shifts commodity price risks to the WFP and food beneficiaries. The United States could procure part of its in-kind contributions to the WFP through forward purchases. As this would provide increased price certainty for American farmers, it may be politically palatable to Congress. Other countries which make in-kind purchases might also consider this approach.

In the wake of the 2009 financial crisis, I am well aware that the appetite for financial innovation may not be large. But the very conservative proposals described here are a far cry from the risky derivatives that fueled the crisis. Simple call options and futures instruments are well proven in large-scale commodity exchanges. The WFP can use these instruments to counter the effects of high and volatile food prices and in turn, feed many more hungry people around the world.

Dr. Paul Kedrosky maintains a widely-read blog on technology finance at Paul.Kedrosky.com (http://paul.kedrosky.com). Earlier in his career, Dr. Kedrosky founded the technology equity research practice at HSBC James Capel. Dr. Kedrosky was one of the first analysts to cover Internet companies,… More

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financial reporting

For Associated Content

Hoorenbeek (HBK:SLCAPEX) & Nestler Investments (NIC:SLCAPEX) resumed trading today after properly posting Financial Reporting for the month of October, however Bogart Beck, SLCAPEX CEO, indicated that changes will go into effect in January 2009 to better streamline the information included in financial reports, moving toward a universal standard, at least for SLCAPEX, of what needs to be identified and accounted for, and how.

In relation to HBK(SLCAPEX) and NIC(SLCAPEX), Beck stated, “We have identified deficiencies in both company's reporting methodologies and are consulting with the Officers of each company to resolve those issues.”

In a statement for Associated Content Bogart Beck explained, ” “We're looking at several policy changes specifically designed to help level the playing field between Investor and listed-company. For example, minimum or continued listing requirements (several viability and solvency tests) as well as a bit more rigidity in the methodologies used for providing Financial Statements.”

Furthermore Beck clarified, “In the end each of the SL Stock Exchanges differentiates based on their own Regulatory viewpoints. There is very little enforceability here after-the-fact therefore we're looking to establish a more meaningful way of helping qualify IPO's and providing reasonable oversight and guidance before companies find themselves in trouble or investors find themselves trying to hunt down CEO's”

A question that poses itself due to it being a metric in the playbook I have always used is “insider trades”. Martin Zweig won't buy anything with insider sales within 6 months. The software for ACE and SLCAPEX doesn't provide this info as readily as the platforms for the other exchanges, so is that something that might become prerequisite for financial statements?

“Regarding insider trading, the system wasn't written with that in mind (though it probably should have). There are ways to manually monitor the trading activity of the high-visibilty insiders and officers (Top 10) but it takes effort.”

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payroll accounting

Time to Pay the Piper? The First Hint of a European-Style VAT
by Michael Reagan

Democrats in Washington haven’t wanted to be terribly forthcoming as to how they intend to pay for the new health care entitlement program and other massive spending programs being passed. It seems our national debt ceiling is now raised every few months, and the federal deficit is higher than it’s ever been — exponentially so.

Well, we can now see why the liberal establishment hasn’t wanted to address the issue head-on with the American people. At a private event the other evening, it has been reported that one of the Obama Administration’s lead economic counselors, Paul Volcker, indicated the support for a Value-Added Tax (VAT) may be more achievable than in the past.

This statement does not surprise me in the least. You see, in order to fund the record spending of the federal government, hard-working families and small businesses are going to be required to foot more of the bill…it is that simple. After passage of a nearly $1 trillion health care bill, the Obama administration cannot longer deny this. The only question in my mind has been how much will our taxes be raised — and when.

A VAT is a tax that is added to a good at each stage of the production process. So when a hypothetical widget’s first component is put together a tax is added. That’s just the start. At each further stage of assembly, development and distribution, a new tax is added, all the way through until final sale. Not surprisingly, VAT taxes are not borne wholly by the producers themselves. Rather those incremental taxes are passed along to consumers in the form of higher prices.

Even most troubling, this tax comes with a complete lack of transparency. Unlike a sales tax, which the consumer sees as a line item on their sales receipt beyond the retail price, a VAT is simply a hidden tax. It is another way for the federal government to take our money and deliberately leave taxpayers in the dark about their share of footing the bloated federal budget.

Now keep in mind, the addition of a VAT would be on top of our already overly burdensome federal tax system — meaning that you would continue to pay your federal income, payroll, capital gains, and estate taxes. Don’t be deceived into seeing this as a sister to the FairTax reform. This is an entirely new accounting which will significantly increase the price of every good you buy.

Some will argue that this unofficial statement by Mr. Volcker was merely just an administration official discussing possible new revenue streams with a friendly audience — not portending things to come. Not so. Things rarely happen from our leaders in Washington by accident. This was the first salvo in what many of us have feared — Democrats gearing up to increase our tax burden by creating a new form of federal taxation.

Those of us who believe that the federal government should learn to do its job with less money, just as the private sector is forced to do, must begin to prepare for this battle. We almost stopped the passage of health care reform despite little time to gear up a national effort in opposition. Short of a procedural maneuver, we would have succeeded.

Here, we have the advantage of time on our side and we must get ready to fight. Fight for smaller, smarter government; fight to keep more of our hard earned dollars; fight against yet another policy that moves us closer to the European Socialist model.

Join me at Reagan PAC at www.thereaganpac.com to join a grassroots force that will help lead the charge in keeping the VAT in Europe from being imported to our shores.

Mike Reagan, the elder son of the late President Ronald Reagan, is spokesperson for The Reagan PAC (www.thereaganpac.com) and chairman and president of The Reagan Legacy Foundation (www.reaganlegacyfoundation.org).©2010 Mike Reagan. Mike’s column is distributed exclusively by: Cagle Cartoons, Inc., newspaper syndicate, and it is licensed to run on TMV in full.

Wednesday, April 28, 2010

Social Security: The Ultimate Ponzi Scheme   [Veronique de Rugy]

Over at the house blog of the Institute for Truth in Accounting, they have a nice side-by-side comparison of the Madoff scheme and the Social Security one. And yet the AARP and the National Committee to Preserve Social Security and Medicare are pushing to have Social Security left out of the deficit commission's deliberations. According to Congressional Quarterly:

“Social Security has not contributed one thin dime to the current deficit,” former Rep. Barbara B. Kennelly, D-Conn. (1982-99), who is president of the National Committee to Preserve Social Security and Medicare, said during a conference call with reporters. “It should not be used as a piggy bank to pay our way out of the fiscal hole we find ourselves in.”

Then she should have made sure that the federal government didn't put its dirty hands on the alleged “lock box” in which payroll taxes were supposed to be held to pay for future retirements. That money — roughly $2.5 trillion for the Social Security trust fund alone, and $4 trillion once we add the other “trust funds” — is long gone. It's been used to pay for wars and education and Head Start and such. Granted, the cash has been replaced by IOUs from the federal government, but, in order for the federal government to pay back Social Security, it will have to borrow the money from the public, increasing the deficit and the national debt, or tax Americans once again. This seems like the biggest rip-off ever.

Megan McArdle, over at The Atlantic, touches on the issue here.

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audit committee

That’s great to hear. And it’s why an open amendment process on the floor is so important.

“The group is actively gathering cosponsors as the Senate continues to vote to break a GOP filibuster which is preventing debate from beginning,” writes Grim.

Ryan Grim, of course, is wrong to say that the Republicans are filibustering, because objecting or threatening to filibuster is not a filibuster. Saying it is only helps Harry Reid to cement default supermajority rule on the Senate where it doesn’t belong. But then, Grim seems to believe he needs to report with a partisan perspective on the doings of the Democrats.

The Senate is continuing to vote on a supermajority 60-vote cloture motion filed by Harry Reid (and 15 colleagues) because Harry Reid won’t force a filibuster. More importantly, however, Reid wouldn’t let the year-long Senate writing of this legislation by members of both Parties on the Banking Committee – unfortunately mostly done out-of-sight and out-of-mind behind closed doors, with the committee markup itself of this complex legislation completed in a disgraceful 21 minutes, without debate or amendment – get to a place where both sides are comfortable opening the floor debate, without fear of a repeat of this from Reid:

Mr. ALEXANDER. Twenty-six times the majority leader has filled the amendment tree. That is a “no” motion that says no more amendments. has done it nearly as much as the last five majority leaders combined. He has the record in saying no more amendments, no more debates, and no more checks and balances on what the Congress is doing. There have been 141 times the majority leader has filed cloture on the same day a measure came up. That is simply another no motion. It says no to more amendments, no to more debates, no to more checks and balances on the legislation Congress is considering.

The Senator from Virginia, who is the Presiding Officer today and my colleague, and Senator Corker from Tennessee worked for a year on this. I went to some of their sessions. It is complex stuff, but they were coming up with a bipartisan solution to the problem. One of the advantages of a bipartisan solution is, A, it might be more likely to be right; and, B, it almost certainly is more likely to be accepted. If there is a Corker-Warner or Warner-Corker solution, Republican-Democratic solution on banks that are too big to fail, then the American people might look up here and say: OK, if they both agree on it, maybe they are right. Maybe I will not worry about it, and I will not spend my next 3 years trying to repeal it. Well, the same thing was true on other parts of the issue, and I commend Senator Dodd, the chairman of the committee, for starting out in that direction. He was working with Senator Shelby on this side on consolidating bank regulators and consumer protection. Senator Reed on the Democratic side and Senator Gregg were working on reforming oversight of derivatives. As I said, Senator Warner and Senator Corker were working on systemic risk, the too-big-to-fail issue. Senator Schumer and Senator Crapo were working on securities and exchange issues and corporate governance issues. They weren’t coming to an agreement on every single one of these issues–the last one is especially difficult–but they are making some real progress. Even yesterday, Senator Shelby, who is the ranking member, and Senator Dodd said on NBC’s “Meet the Press”–Senator Shelby said: “We are closer than we have ever been.” Mr. Dodd added: “We will get it together.”

Well, if we are closer than we have ever been and we will get it together, why are we having this “no” vote today? Why are we saying no to more amendments, no to more debate, no to checks and balances?

http://frwebgate.access.gpo.gov/cgi-bin/getpage.cgi?dbname=2010_record&page=S2609&position=all

Reporters like Grim who cover Capitol Hill ought to know by now, and be able to explain, that when a bill is allowed to come to the floor for “debate and amendment” in the current Democratic Senate, there is no guarantee under Harry Reid that genuine “debate and amendment” will be allowed to take place. [See the health care reform "debate," see the lockstep Democratic blocking of all amendments during the follow-up reconciliation process, etc., etc.]

It does no one any good to call objections to proceeding by a small Senate minority, which suspects they will be prevented from participating in an open amendment process, a “filibuster,” as Grim misleadingly does here.

And it definitely does the American people no favor to characterize efforts to safeguard the minority’s voice in the Senate – and in fact the democratic legislative process itself – as efforts to protect and serve Wall Street, as a series of Democrats have been doing in self-righteous tones since the cloture vote yesterday failed – to attempt to pump up their Party’s political prospects, even as they disingenuously ignore their powerful majority Party’s own responsibility for the state of affairs in the Senate.

As Chris Dodd himself pointed out yesterday on the floor:

Frankly, I don’t think it serves our interests well to be screaming at each other about who cares more about this issue than the other. I think it unfortunate that a number of my Republican friends who I know care about this very much would be branded that somehow they don’t care about it to such an extent that they would not even let it get to a debate. They have ideas on this legislation. They want their amendments considered and they don’t want to be told you cannot even do that because we do not have some large, sweeping agreement on a bill here.

If Dodd’s word can be trusted, he may have finally started to change the game on this bill with a statement I just heard him make on the floor this afternoon, to the effect that:

“As Chairman of the committee, I will insist that every Senator [all 100] have a right to be heard and to offer their amendments on the floor” [if the motion to proceed is adopted].

If Dodd can carry through on that, and if Republicans trust him to do so, they may well agree to proceed to floor debate, in the belief that this time Reid won’t fill the amendment tree, or require 60-vote margins for passage of amendments, or force Party-line votes on amendments that would prevent Republicans from having a chance to change the bill. We’ll see…

With regard to the Federal Reserve audit, and the Fed’s responsibilities in general, note how Senator Warner described the failure of the Fed to act to regulate mortgages, also yesterday:

Mr. WARNER. Think about the fact back in the early 1990s, back in 1993, Congress actually passed legislation to give the Federal Reserve the responsibility to regulate mortgages–responsibility that we have seen time and again they didn’t take up the challenge to meet.

As unusual a coalition as can be crafted in the Senate plans to
fight for an amendment to the Wall Street reform bill that would open
the Federal Reserve to a serious audit by the Government Accountability
Office. Sponsored by Sen. Bernie Sanders (I-Vt.), the language is
modeled after an amendment that passed the House, sponsored by Reps.
Alan Grayson (D-Fla.) and Ron Paul (R-Texas).

Sanders is joined by four Republicans of varying politics: John
McCain (Ariz.), Jim DeMint (S.C.), David Vitter (La.) and Sam Brownback
(Kan.). If Democrats in the Senate back the measure, it would have at
least 63 votes, but Banking Committee Chairman Chris Dodd (D-Conn.) is
opposed and has argued against a broad audit.

The chairman of the Judiciary Committee, Sen. Pat Leahy (D-Vt.), is
also a cosponsor, as is Sen. Russ Feingold (D-Wisc.). The group is
actively gathering cosponsors as the Senate continues to vote to break
a GOP filibuster which is preventing debate from beginning.

Needless to say, Zero Hedge fully endorses anything that will make the destruction of America at least a moderately more prolonged affair.

Full letter:

Support the
Sanders-Feingold-DeMint-Leahy-McCain-Vitter-Brownback Federal Reserve
Transparency Amendment to the Financial Reform Bill

The American people have a right to know who received over $2 Trillion in financial assistance from the Federal Reserve.

Since the beginning of the financial crisis, the Federal Reserve has
provided over $2 trillion in taxpayer-backed loans and other financial
assistance to some of the largest financial institutions and
corporations in the world. Unfortunately, the Fed is still refusing to
tell the American people or the Congress who received most of this
assistance, how much they received or what they are doing with this
money. This money does not belong to the Federal Reserve, it belongs to
the American people, and the American people have a right to know where
their taxpayer dollars are going.

Therefore, during the consideration of the financial reform bill, we
will offer an amendment to increase transparency at the Federal
Reserve. Specifically, our amendment:

* Requires the non-partisan Government Accountability Office (GAO) to
conduct an independent and comprehensive audit of the Federal Reserve
within one year after the date of enactment of the financial reform
bill;

* Requires the GAO to submit a report to Congress detailing its
findings and conclusion of their independent audit of the Fed within 3
months; and

* Requires the Federal Reserve within one month after the date of
enactment to disclose the names of the financial institutions and
foreign central banks that received financial assistance from the Fed
since the start of the recession, how much they received, and the exact
terms of this taxpayer assistance.

* Does not interfere with or dictate the monetary policies or decisions of the Federal Reserve.

59 Senators, 320 Members of Congress, and two federal courts have called on the Federal Reserve to become more transparent.

Our amendment is similar to an amendment that was offered to last
year's Budget Resolution that passed the Senate on a bi-partisan vote
of 59-39 on April 1, 2009; S.604, the Federal Reserve Sunshine Act that
now has 33 bi-partisan co-sponsors; and the Federal Reserve
Transparency Act (H.R. 1207) that has 320 bi-partisan co-sponsors (a
version of which passed the House Financial Services Committee by a
vote of 43-28 and was incorporated into the financial reform bill that
passed the House last December).

In August of 2009, the United States District Court for the Southern
District of New York also ordered the Fed to disclose the recipients of
this taxpayer assistance as a result of a Freedom of Information Act
lawsuit filed by Bloomberg News. This decision was upheld by the U.S.
Court of Appeals in Manhattan on March 19, 2010.

The Senate Financial Reform Bill does not do enough to make the Fed more transparent.

While the Senate financial reform bill attempts to address the lack of
transparency at the Fed, as currently drafted, much of the information
regarding the details of who received this financial assistance could
be kept secret forever.

As long as the Federal Reserve is allowed to keep the information on
their loans secret, we may never know the true financial condition of
the banking system. The lack of transparency at the Fed could lead to
an even bigger crisis in the future.

We now know that the lack of transparency in credit default swaps led
to the $182 billion taxpayer bailout of AIG; the collapse of Lehman
Brothers and precipitated the worst financial crisis since the Great
Depression.

We know who received TARP funding.

Anyone with access to the internet can go onto the Treasury
Department's website and find out exactly who received a bail-out from
the $700 billion TARP program. The American people have a right to know
the same information from the Fed.

The Sanders Amendment does not undermine the Fed's independence.

This amendment does not take away the “independence” of the Fed and it does not put monetary policy into the hands of Congress.

This amendment does not tell the Federal Reserve when to cut short-term
interest rates or when to raise them. It does not tell the Federal
Reserve what banks to lend money to and what banks not to lend money
to. It does not tell the Federal Reserve what foreign central banks
they can do business with and which ones it cannot do business with. It
does not impose any new regulations on the Federal Reserve nor does it
take any regulatory authority away from the Fed.

This amendment simply requires the GAO to conduct an independent audit
of the Fed and requires the Fed to release the names of the recipients
of more than $2 trillion in taxpayer-backed assistance.

For nearly nine decades, the GAO has a proven track record of
conducting objective, fact-based, nonpartisan, non-ideological, fair,
and balanced audits. Through these audits, the GAO helped save the
American taxpayers $50 billion last year alone by rooting out waste,
fraud, and abuse in the federal government.

Let's not equate independence with secrecy. We cannot let the Fed
operate in secrecy any longer. There is simply too much money at stake.

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Hello world!

Köszöntünk az Ingyenblog.hu-n. Ez az első bejegyzésed.

Most válassz ki egy Neked tetsző sablont a vezérlőpulton (Megjelenés/Sablonok), és állítsd be, majd kezd el a blogolást a Bejegyzések-re kattintva!

Jó blogolást!

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