Chapter 4 Karla Johnstone

Auditing
A Risk-Based Approach To Conducting A Quality Audit

10th edition
Karla M. Johnstone | Audrey A. Gramling | Larry E. Rittenberg
CHAPTER 4
PROFESSIONAL LIABILITY, AUDITOR JUDGMENT

FRAMEWORKS, AND PROFESSIONAL RESPONSIBILITIES
Copyright © 2016 South-Western/Cengage Learning

LEARNING OBJECTIVES
1. Discuss the liability environment in which auditors

operate and explore the effects of lawsuits on audit
firms
2. List laws from which auditor liability is derived and
describe the causes of legal action against auditors
3. Describe auditor liability under contract law,
common law, and statutory law
4-2
LEARNING OBJECTIVES
4. Articulate a framework for making quality

professional decisions and apply this framework in
selected audit settings
5. Articulate a framework for making quality ethical
decisions and apply this framework in selected
settings
6. Identify guidance on auditors’ professional
responsibilities and make audit decisions informed
by the appropriate professional guidance.
4-3
THE AUDIT OPINION FORMULATION
PROCESS
4-4
PROFESSIONAL JUDGMENT IN
CONTEXT
• Adams repeatedly accepted tens of thousands of
dollars in casino markers from an audit client, while
he was the advisory partner on Deloitte & Touche’s
audit of that client, a casino gaming corporation
• The audit client filed its annual report with the SEC,
including a D&T audit report that stated that its audit
had been conducted in accordance with the
standards of the PCAOB.
• Because of Adams’ conduct described above, that
statement was incorrect.
4-5
PROFESSIONAL JUDGMENT IN
CONTEXT
• What is appropriate professional conduct for
auditors and what guidance exists related to
auditors’ professional responsibilities? (LO 6)
• What types of auditor actions could lead to

litigation? (LO 2)
• What actions can auditors and audit firms take to

encourage appropriate professional conduct and
minimize litigation exposure? (LO 3, 4, 5, 6)
4-6
LEARNING OBJECTIVE 1
DISCUSS THE LIABILITY ENVIRONMENT IN

WHICH AUDITORS OPERATE AND EXPLORE THE
EFFECTS OF LAWSUITS ON AUDIT FIRMS

EFFECTS OF LAWSUITS ON AUDIT FIRMS
• Litigation cases are expensive for audit firms

• Result in monetary losses
• Consume time of audit firm members
• Hurt their reputation
• Practice protection costs are second-highest costs for
audit firms after employee compensation costs
4-8
REASONS FOR LITIGATION AGAINST AUDIT
FIRMS
• Liability doctrines permit a recovery of full amount of
settlement from an external audit firm even though
that firm is found to be only partially responsible for
the loss
• Deep-pocket theory: Suing another party based on
perceived ability of that party to pay damages
• Class action suits and associated user awareness of
possibilities and rewards of litigation
4-9
REASONS FOR LITIGATION AGAINST AUDIT
FIRMS
• Contingent-fee-based compensation for law firms
• Misunderstanding by some users of financial
statements that an unqualified audit opinion
represents an insurance policy against investment
losses
4-10
LIABILITY DOCTRINES
• Joint and several liability: Apportions losses among
all defendants who have an ability to pay for
damages, regardless of level of fault
• Designed to protect users suffering losses because of
misplaced reliance on materially misstated financial
statements
4-11
LIABILITY DOCTRINES
• Private Securities Litigation Reform Act (PSLRA) of
1995
• Designed to curb frivolous securities class action
lawsuits brought under federal securities laws against
low performing stock of companies
• Liability is proportional unless auditor knowingly
participated in a fraud
• Proportionate liability: Payment by an individual
defendant based on degree of fault
4-12
CLASS ACTION LAWSUITS
• Brought on behalf of a large group of plaintiffs to:
• Consolidate lawsuits
• Encourage consistent judgments
• Minimize litigation costs
• Plaintiff shareholders may bring suit for themselves
and all others in a similar situation
• Allows underprivileged individuals to seek
compensation for damages
4-13
CONTINGENT-FEE COMPENSATION FOR
LAWYERS
• Lawyers work on contingent fee basis
• Contingent fee: Depends on finding or results of
services
• Contingent-fee cases: Lawsuits brought by plaintiffs
with compensation for their attorneys being
contingent on the outcome of the litigation
4-14
AUDITS VIEWED AS AN INSURANCE POLICY
• Expectations gap: Shareholders mistakenly believe

that they are entitled to recover losses on
investments for which auditor provided unqualified
opinion on financial statements
• Encourages large lawsuits against auditors even for
cases when auditor is partially or not at fault
4-15
LIST LAWS FROM WHICH AUDITOR LIABILITY IS

DERIVED AND DESCRIBE THE CAUSES OF LEGAL
ACTION AGAINST AUDITORS

LAWS FROM WHICH AUDITOR
LIABILITY IS DERIVED
• Common law: Liability concepts developed through court
decisions based on negligence, gross negligence, or fraud
• Contract law: Liability occurred where there is a breach
of contract
• Contract is between external auditor and client for
performance of financial statement audit
• Statutory law: Developed through legislation
• Securities Act of 1933
• Securities Exchange Act of 1934
• Sarbanes-Oxley Act of 2002
4-17
CAUSES OF LEGAL ACTION
• Breach of contract
• Failure to perform a contractual duty that has not been
excused
• For audit firms, parties to a contract include clients and
designated third-party beneficiaries
4-18
• Negligence: Failure to exercise reasonable care,
thereby causing harm to another or to property
• Gross negligence
• Failure to use minimal care or evidence of activities
that show a recklessness or careless disregard for truth
• Evidence may not be present, but inferred by jury
because of carelessness of defendant’s conduct
4-19
• Fraud: Intentional concealment or misrepresentation
of a material fact
• Intending to deceive another person
• Causing damage to deceived person
• Scienter: Knowledge on part of person making
representations, at the time they are made, that they
are false
4-20
PARTIES THAT MAY BRING SUIT
AGAINST AUDITORS
• Client and third-party users - Anyone who can
support a claim that damages were incurred based
on misleading audited financial statements can bring
a claim against an auditor
• Can accuse auditor of:
• Breach of contract
• Tort: A civil wrong, other than breach of contract, based
on negligence, constructive fraud, or fraud
4-21
EXHIBIT 4.1 - OVERVIEW OF AUDITOR
LIABILITY
4-22
DESCRIBE AUDITOR LIABILITY UNDER

CONTRACT LAW, COMMON LAW, AND
STATUTORY LAW

COMMON-LAW LIABILITY TO CLIENTS -
BREACH OF CONTRACT
• Auditors are expected to fulfill contractual
responsibilities to clients
• Can be held liable to clients under contract law and/or
under common law for breach of contract
• Can be sued under concepts of negligence, gross
negligence, and fraud
4-24
BREACH OF CONTRACT
• Causes for action against auditor for breach of
contract
• Violating client confidentiality
• Failing to provide audit report on time
• Failing to discover a material error or employee fraud
• Withdrawing from an audit engagement without
justification
4-25
BREACH OF CONTRACT
• Remedies for breach of contract
• Requires specific performance of contract agreement
• Grant of an injunction to prohibit auditor from doing
certain acts
• Provide for the recovery of amounts lost as a result of
breach
• When an injunction is not appropriate the client is
entitled to recover compensatory damages
4-26
BREACH OF CONTRACT
• Auditor’s arguments as defenses against a breach of
contract suit
• Auditor exercised due professional care in accordance
with contract
• Client was contributory negligent
• Client’s losses not caused by breach
4-27
COMMON-LAW LIABILITY TO THIRD
PARTIES
• To win a claim against the auditor, third parties suing
under common law must prove that:
• They suffered a loss
• The loss was due to reliance on misleading financial
statements
• The auditor knew, or should have known, that financial
statements were misleading
4-28
DIFFERING REQUIREMENTS FOR
AUDITOR LIABILITY TO THIRD PARTIES
• Foreseeability and negligence: Common Law
• The Ultramares case: Third-party beneficiary test
• Expansion of Ultramares: Identified user test
• Foreseen user test
• Foreseeable user test
4-29
FORESEEABILITY AND NEGLIGENCE
• Critical point in determining the type of claim is the
likelihood that an auditor could foresee the user
relying upon audited financial statements
• Less foreseeable plaintiffs need to establish a gross
negligence claim
• Foreseeable users, in some jurisdictions, have to
establish only a negligence claim
4-30
THE THIRD-PARTY BENEFICIARY TEST
• New York Court of Appeals in 1931, Ultramares
Corporation v. Touche case
• Court held auditors liable to third parties for fraud and
gross negligence, but not for negligence
• Third-party beneficiary: A person who was not a party
to a contract, but is named in contract as one to
whom contracting parties intended that benefits be
given
• For liability to be established, a third-party beneficiary
must be specifically identified as a user
4-31
THE IDENTIFIED USER TEST
• Credit Alliance Corp. v. Arthur Andersen & Co., New
York Court of Appeals extended auditor liability for
ordinary negligence to identified users
• Identified user: The auditor has specific knowledge
that known users will be utilizing financial statements
in making specific economic decisions
4-32
FORESEEN USER TEST
• Restatement (Second) of Torts expanded auditor
liability for negligence to:
• Identified users
• Foreseen users: Individually unknown third parties
who are members of a known or intended class of
third-party users who the auditor can foresee will use
the statements
• Client must inform auditor that third parties intend to use
financial statements
• Auditor does not have to know identity of third party
4-33
FORESEEABLE USER TEST
• Some courts have extended auditor liability to
foreseeable users of audited financial statements
• Foreseeable users:
• Not known by auditors to be using financial statements
• Recognized by general knowledge as current and
potential creditors and investors who will use them
4-34
EXHIBIT 4.2 - FORESEEABILITY CONCEPTS FOR
AUDITOR’S COMMON-LAW LIABILITY TO THIRD PARTIES
4-35
AUDITOR LIABILITY UNDER STATUTORY
LAW
• Primary federal statutes affecting auditor liability for
public clients
• Securities Act of 1933
• Securities Exchange Act of 1934
• Sarbanes-Oxley Act of 2002
• Enacted to assure that investors in public companies
have access to full and adequate disclosure of
relevant information
4-36
SECURITIES ACT OF 1933
• Requires companies to file registration statements
with the SEC before issuing new securities to public
• Registration statement contains:
• Information about company itself
• Lists of its officers and major stockholders
• Plans for using proceeds from new securities issue
4-37
• Prospectus
• First part of a registration statement filed with SEC
• Issued as part of a public offering of debt or equity
• Used to solicit prospective investors in a new security
issue containing, among other items, audited financial
statements
• Securities Act of 1933 imposes liability for
misstatements in a prospectus
4-38
• Section 11
• Most important liability section from the perspective
of external auditors
• It imposes penalties for misstatements contained in
registration statements
• Accuracy of registration statement is determined at its
effective date
4-39
• SEC intends to assure full and fair disclosure of public
financial information
• An auditor may be held liable to purchasers of
securities for negligence, or gross negligence and
fraud
• Purchasers need to prove that:
• They incurred a loss
• Financial statements were materially misleading or not
fairly stated
4-40
• In their defense, auditors must prove that:
• Due professional care was used
• Statements were not materially misstated
• The purchaser did not incur a loss caused by the
misleading financial statements
4-41
SECURITIES EXCHANGE ACT OF 1934
• Regulated companies are required to file periodic
reports with the SEC and stockholders
Annual reports to shareholders and 10-Ks
• Annual reports filed with the SEC
• Both contain audited financial statements
• 10-Ks must be filed within 60 to 90 days of the end of the fiscal
year
Quarterly financial reports to shareholders and 10-Qs
• Quarterly reports filed with the SEC
• 10-Qs must be filed within 40 to 45 days of end of each of first
three quarters
• 10-Qs must be reviewed by auditors
8-Ks
• Reports filed with the SEC describing occurrence of important
events
4-42
• Prohibits material misrepresentations or omissions
and fraudulent conduct
• Provides a general antifraud remedy for purchasers
and sellers of securities
• Auditor may be held liable for fraud when a plaintiff
alleges being misled by misstatements in financial
statements
4-43
• Act makes it unlawful to:
• Make any untrue statement of a material fact
• Omit to state a material fact necessary for
understanding financial statements
• Basic elements for a successful case for securities
fraud
• Material misrepresentation or omission
• Fraudulent conduct in connection with purchase or sale of a
security
4-44
• Scienter, when making the misrepresentation or omission
• Reliance upon fraudulent conduct
• Measurable monetary damages
• A causal connection between misrepresentation or
omission and economic loss
• Showing compliance with generally accepted
accounting principles (GAAP) is an acceptable
defense by an auditor
4-45
• Criminal actions against auditors who:
• Willfully violate provisions of either Act and related rules
or regulations
• Know that financial statements are false and misleading
and who issue inappropriate opinions
• Resolutions in these cases
• Injunctions and disgorgement orders
• Civil penalties
• Suspending individuals from serving as directors of
securities issuers or participating in securities industry
4-46
AUDITOR LIABILITY UNDER STATUTORY
LAW
• Auditors found unqualified, unethical, or in willful
violation of any provision of federal securities laws can
be sanctioned by SEC
• Temporarily or permanently revoking the firm’s
registration with the PCAOB, meaning that the SEC will not
accept its audit reports
• Imposing civil monetary penalties
• Requiring special continuing education of firm personnel
• Suspending individuals from serving as officers or directors
of securities issuers or participating in the securities
industry
4-47
ARTICULATE A FRAMEWORK FOR MAKING

QUALITY PROFESSIONAL DECISIONS AND APPLY
THIS FRAMEWORK IN SELECTED AUDIT SETTINGS

A FRAMEWORK FOR PROFESSIONAL
DECISION MAKING
• Quality decisions of auditors
• Add value to financial markets
• Unbiased
• Meet expectations of users
• Comply with professional standards
• Based on sufficient factual information to justify the
decision that is rendered
4-49
EXHIBIT 4.3 - A FRAMEWORK FOR
PROFESSIONAL DECISION MAKING
4-50
STEPS IN DECISION MAKING
• Step 1 - Auditor structures the problem
• Consider relevant parties to involve in the decision
process
• Identify and consider evaluation of various feasible
alternatives
• Identify uncertainties or risks
• Step 2 - Auditor assesses consequences of alternatives
• Determining and weighing dimensions on which to
evaluate the alternatives
4-51
• Step 3 - Auditor assesses the risks in the situation
• Risks the audit client faces
• Quality of evidence the auditor gathers
• Sufficiency of audit evidence gathered
• Step 4 - Auditor evaluates the various
information/audit evidence
• Decision rules are articulated in terms of generally
accepted accounting principles or auditing standards
4-52
• Step 5 - Auditor considers the sensitivity of the
conclusions reached in earlier steps
• Professional judgment: Application of professional
knowledge to facts and circumstances to reach a
conclusion or make a decision
• Client and auditor use their professional judgment to
determine a value most reflective of economic reality
4-53
• Step 6 - Auditor gathers information in an iterative
process that affect considerations about
consequences and uncertainties of potential
alternatives
• Costs and benefits of information acquisition
considered
• Step 7 - Auditor needs to decide whether:
• The problem has been sufficiently analyzed
• The risk of making an incorrect decision has been
minimized
4-54
IMPORTANCE OF SKEPTICISM IN
MAKING PROFESSIONAL JUDGMENTS
• A professionally skeptical auditor will:
• Critically question contradictory audit evidence
• Carefully evaluate reliability of audit evidence
• Reasonably question authenticity of documentation
• Reasonably question honesty and integrity of:
• Management
• Individuals charged with governance
• Third party providers of audit evidence
4-55
IMPORTANCE OF SKEPTICISM IN
MAKING PROFESSIONAL JUDGMENTS
• Tips to encourage skeptical mindset
• Be sure to collect sufficient evidence
• When evidence is contradictory, be diligent in evaluating
reliability of individuals or processes
• Generate independent ideas about reasons for
unexpected trends or financial ratios
• Question trends that appear too good
• Wait to make professional judgments until facts known
• Have confidence in your knowledge to understand
complex situations
4-56
ARTICULATE A FRAMEWORK FOR MAKING

QUALITY ETHICAL DECISIONS AND APPLY THIS
FRAMEWORK IN SELECTED SETTINGS

RESOLVING ETHICAL DILEMMAS
• Ethical dilemma:
• A situation in which moral duties or obligations conflict
• An ethically correct action may conflict with an
individual’s immediate self-interest
• Ethical theories help in dealing with ethical dilemmas
• Utilitarian theory
• Rights theory
4-58
UTILITARIAN THEORY
• Suggests that ethical is the action that achieves the
greatest good for the greatest number of people
• Requirements
• An identification of the potential problem and possible
courses of action
• An identification of the potential direct or indirect
impact of actions on each affected party
• An assessment of the desirability of each action
• An overall assessment of the greatest good for the
greatest number
4-59
PROBLEM WITH UTILITARIAN THEORY
• This approach can lead to disastrous courses of
actions when those making decisions fail to
adequately measure or assess potential costs and
benefits
4-60
RIGHTS THEORY
• Identifies a hierarchy of rights that should be
considered in solving ethical dilemmas
• Based on fundamental rights of parties involved
• Higher order rights take precedence over lower order
rights
• Most effective in identifying outcomes that ought to
be automatically eliminated
4-61
HIERARCHY OF RIGHTS
• Include the right to life, to autonomy, and to human dignity

Highest
order
• Include rights granted by government

Second- • Civil rights, legal rights, rights to own property, and license privileges
order
• Related to social rights

Third- • Right to education, to good health care, and to earning a living
order
• Related to one’s nonessential interests or one’s personal tastes

Fourth-
order
4-62
EXHIBIT 4.4 - A FRAMEWORK FOR
ETHICAL DECISION MAKING
4-63
IDENTIFY GUIDANCE ON AUDITORS’

PROFESSIONAL RESPONSIBILITIES AND MAKE
AUDIT DECISIONS INFORMED BY THE
APPROPRIATE PROFESSIONAL GUIDANCE.

INTERNATIONAL ETHICS STANDARDS BOARD FOR
ACCOUNTANTS (IESBA) CODE OF ETHICS FOR
PROFESSIONAL ACCOUNTANTS
• The Code requires auditors to adhere to fundamental
principles
• Integrity
• Objectivity
• Professional competence and due care
• Confidentiality
• Professional Behavior
• The Code also contains specific standards addressing
many of the topics contained in the AICPA Code of
Professional Conduct
4-65
AICPA CODE OF PROFESSIONAL
CONDUCT
• Principles of professional conduct
• Broad principles that articulate auditors’
responsibilities and their requirements to:
• Act in the public interest
• Act with integrity and objectivity
• Be independent
• Exercise due care
• Perform an appropriate scope of services
4-66
AICPA RULES OF CONDUCT
• Rules of conduct
• Detailed guidance to assist an auditor in applying
broad principles contained in AICPA’s Code of
Professional Conduct
• Rules evolved over time as members of profession
encountered specific ethical dilemmas in complying
with principles of the Code
4-67
INDEPENDENCE - RULE 101
• External auditors required to be independent when
providing services to either public or private entities
• Specific rulings provide detailed guidance on such
matters as:
• Financial interests in the client
• Family relationships
• Loans with a client
• Performance of nonaudit services
4-68
INTEGRITY AND OBJECTIVITY - RULE
102
• AICPA members required to act with integrity and
objectivity in all services that may be provided to a
client
• Applies to CPAs who are not in public practice
• CPA - Special certificate that holds its owner to a high
standard of ethical conduct
4-69
GENERAL STANDARDS - RULE 201
• Members required to comply with following
standards and with any interpretations thereof by
bodies designated by Council
• Professional competence
• Due professional care
• Planning and supervision
• Sufficient relevant data
4-70
COMPLIANCE WITH STANDARDS -
RULE 202
• Members performing following tasks required to
comply with standards promulgated by bodies
designated by Council
• Auditing
• Review
• Compilation
• Consulting
• Tax
• Other professional services
4-71
ACCOUNTING PRINCIPLES - RULE 203
• When financial statements are not in conformance
with GAAP, members not allowed to:
• Express an opinion that financial data are presented in
conformity with generally accepted accounting
principles or
• State unawareness regarding any material
modifications that should be made to financial data to
be in conformity with generally accepted accounting
principles
4-72
CONFIDENTIALITY - RULE 301
• Client must be assured that auditor will not
communicate confidential information to outside
parties
• Privileged communication: Information about a
client that cannot be subpoenaed by a court of law
to be used against a client
• Most states allow privileged communication for
lawyers, but not for auditors
4-73
• Auditors not restricted from communicating
information for the following purposes
• To assure adequacy of accounting disclosures required
by GAAP
• To comply with a validly issued and enforceable
subpoena or summons or with applicable laws and
government regulations
4-74
• To provide relevant information for an outside quality
review of firm’s practice under PCAOB, AICPA, or state
board of accountancy authorization
• To initiate a complaint with or responding to an inquiry
made by:
• AICPA’s professional ethics division
• Trial board or investigative or disciplinary body of a state
CPA society or board of accountancy
4-75
CONTINGENT FEES - RULE 302
• Contingent fee: Charged for performance of any
service
• A fee will not be collected unless a specified finding or
result is attained, or in which amount of fee depends
on the finding or results of such services
• Contingent fees are not allowed for audit engagements
4-76
ACTS DISCREDITABLE - RULE 501
• Members not allowed to commit an act discreditable
to the profession
4-77
ADVERTISING AND OTHER FORMS OF
SOLICITATION - RULE 502
• Members in public practice not allowed to seek
clients by advertising or other forms of solicitation in
a false, misleading, or deceptive manner
• Solicitation by use of coercion, overreaching, or
harassing conduct is prohibited
4-78
COMMISSIONS AND REFERRAL FEES -
RULE 503
• Commissions prohibited for:
• Recommendation or referring to a client any product
or service
• Recommendation or referring any product or service to
be supplied by a client
• Members or the members’ firms performing
attestation services for client
4-79
COMMISSIONS AND REFERRAL FEES -
RULE 503
• Disclosure of permitted commissions:
• Members not prohibited from performing services or
receiving commission discloses that fact to any person or
entity to whom product or service is recommended or
referred
• Referral fees:
• Any member who accepts a referral fee for recommending
or referring any service of a CPA to any person or entity or
who pays a referral fee to obtain a client shall disclose
such acceptance or payment to the client
4-80
FORM OF ORGANIZATION AND NAME -
RULE 505
• Members allowed to practice public accounting only
in a form of organization permitted by state law or
regulation
• Members not allowed to practice public accounting
under a firm name that is misleading
4-81
EMERGING ISSUE
• AICPA Revises Code of Professional Conduct
• The AICPA’s Professional Ethics Executive Committee
(PEEC) adopted a revised Code in January 2014, with
an effective date of December 15, 2014. Additionally,
the Code includes two conceptual frameworks with a
delayed effective date of December 15, 2015.
• More user-friendly, which resulted in a number of
improvements and some substantive revisions
4-82
ENFORCEMENT OF THE CODE OF
PROFESSIONAL CONDUCT
• Compliance with Code depends on:
• Voluntary cooperation of AICPA members
• Public opinion and reinforcement by peers
• Disciplinary proceedings by the Joint Ethics
Enforcement Program
• Sponsored by the AICPA and state CPA societies
4-83
OTHER GUIDANCE
• The Sarbanes-Oxley Act, the PCAOB, and the SEC also
have requirements for professional responsibilities
for audits of public companies. Many of these
requirements are similar to those of the AICPA.
• Additional requirements address:
• Preapproval of services
• Fee disclosures
• Rotation
• Additional prohibited nonaudit services
4-84

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Auditing

A Risk-Based Approach To Conducting A Quality Audit

Karla M. Johnstone | Audrey A. Gramling | Larry E. Rittenberg

PROFESSIONAL LIABILITY, AUDITOR JUDGMENT

Copyright © 2016 South-Western/Cengage Learning

1. Discuss the liability environment in which auditors

4. Articulate a framework for making quality

• What types of auditor actions could lead to

• What actions can auditors and audit firms take to

DISCUSS THE LIABILITY ENVIRONMENT IN

Copyright © 2016 South-Western/Cengage Learning

• Litigation cases are expensive for audit firms

• Expectations gap: Shareholders mistakenly believe

LIST LAWS FROM WHICH AUDITOR LIABILITY IS

Copyright © 2016 South-Western/Cengage Learning

DESCRIBE AUDITOR LIABILITY UNDER

Copyright © 2016 South-Western/Cengage Learning

ARTICULATE A FRAMEWORK FOR MAKING

Copyright © 2016 South-Western/Cengage Learning

ARTICULATE A FRAMEWORK FOR MAKING

Copyright © 2016 South-Western/Cengage Learning

• Include the right to life, to autonomy, and to human dignity

• Include rights granted by government

• Related to social rights

• Related to one’s nonessential interests or one’s personal tastes

IDENTIFY GUIDANCE ON AUDITORS’

Copyright © 2016 South-Western/Cengage Learning

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