Letter from Ernst & Young (ADT 30)
We welcome this inquiry from the House of Lords
Economic Affairs Committee as an opportunity for an open dialogue
with Parliament, regulators and the general public about the issues.
We are pleased to submit evidence in response to it.
Ernst & Young is one of the largest global
professional services organisations. We provide audit, accounting,
tax, corporate finance and other business advisory services to
businesses of all sizes in all sectors; not just financial services.
Our UK activities are overseen by the Institute of Chartered Accountants
in England & Wales, with further supervision over certain
parts of our business by the Financial Reporting Council (FRC),
its Operating Bodies and the Financial Services Authority (FSA).
In preparing our evidence, we consulted with
other member firms in the Ernst & Young network.
We attach a two-page summary and an eight-page
Appendix in which we set out our answers to the Committee's specific
questions.
For further information or to discuss this submission,
please contact Andrew Hobbs, Director, Regulatory & Public
Policy, using the contact details above. We would also welcome
further conversations with you and the Committee's advisor Professor
Chambers. We would be happy to elaborate on any of the points
made in this letter at the forthcoming oral evidence session.
SUMMARY
Competition and choice
1. The UK market for audits of large listed
companies is highly competitive. That said, we recognise that
concentration of auditor choice is an important issue. Ideally,
there should be more choice in the large listed company audit
market. As we have consistently said, we are in favour of promoting
the capability of the mid-tier audit firms through market-based
initiatives that remove any barriers to entry or expansion that
may exist. We do not share the perception that only the Big 4
networks have the depth and reach to participate in the market
for large listed company audits.
How has Ernst & Young responded to the crisis?
2. Like many others, we have used the financial
crisis to consider how we can improve what we do as well as to
consider the role of our profession as a whole. Here are a few
key examples relevant to the Committee's inquiry.
3. To provide the highest quality audits,
we believe we need to be as globally integrated as possible. Thus
we have continued to move forward to integrate our organisation
internationally. This is enabling us to be more effective at identifying
accounting, risk and reporting issues and communicating with clients
about them. We also continue to review our own internal processes
to identify areas for improvement. For example, we have continued
to integrate our financial services practice, have enhanced our
(independent) engagement quality reviews, and deployed scarce
specialist skills across boundaries.
4. Independent non-executives will join
Ernst & Young's Global Advisory Council, the highest global
governance body in the Ernst & Young organisation, to advise
on the public interest aspects of Ernst & Young's decision
making, risk management and stakeholder dialogue.
5. Since the crisis began we have contributed
to UK initiatives to develop policy affecting corporate governance,
financial reporting and the audit profession, including the Walker
Review, UK Corporate Governance review, audit firm governance,
FSA regulatory reform and the FRC's various guidance on going
concern.
What needs to change?
6. All stakeholders need to reflect on the
crisis and challenge the status quo. The audit profession is no
exception.
7. Global coordination is a necessity, not
a luxury, in today's interconnected and interdependent markets.
Regulators and standard-setters need to continue to work together
to achieve global consistency. Effective audit oversight is an
important part of this. With more than 140,000 people working
in more than 140 countries, Ernst & Young would welcome much
greater connectivity and coordination between national audit oversight
bodies. In financial reporting, the lack of progress in achieving
a single set of high quality global accounting standards has been
particularly disappointing.
8. Strong corporate governance is fundamental
to a company's health and to the well-being of our economy. Seeking
to strengthen the corporate governance framework holistically,
rather than focussing on some of its individual components, should
be at the heart of any proposals for change.
9. We have also turned our minds specifically
to the question of corporate reporting and auditing. Financial
statements are prepared by companies and the accounting judgments
are the responsibility of management and the directors. They are
a historic snapshot of a company's financial health. A statutory
audit is an examination of a company's financial statements carried
out in accordance with independently prescribed auditing standards.
After the audit is completed, the auditor issues an audit opinion
which is published as part of the financial statements. It states
whether or not the financial statements show a true and fair view
of the company's business operations and financial health during
the period covered. It is designed to provide reasonable (not
absolute) assurance that the company's financial statements are
free from material misstatement.
10. Except for the going concern statement,
the audit does not provide any assurance about a company's future
performance because financial statements are backward-looking.
11. We believe the current reporting and
auditing model delivers significant value to users. In light of
the crisis, some stakeholders have questioned this value. We are
always open to any positive change that enhances stakeholder confidence
and which improves audit quality. We would support the following
enhancements:
(a) Strengthening audit committees so they are
better placed to challenge management, auditors and their respective
judgements. Such strengthening would also better equip them to
support the auditor's dealings with management.
(b) Better reporting by audit committees and/or
auditors about the existing value of audit and how auditors discharge
their professional responsibilities.
(c) New high quality disclosures to help companies
provide a fuller picture of their financial position, business
model and future viability. Enhanced assurance over these disclosures
would also be required. The key objective should be specific reporting
which avoids boilerplate language. Liability risks present challenges
to this objective. Safe harbours for management, audit committees
and auditors should be explored.
(d) We also support a greater role for auditors
in prudential regulation. This would include a regular dialogue
between bank auditors and supervisors to share in both directions
as much information as possible relevant to their respective roles;
and in carrying out their prudential responsibilities, supervisors
could make more and better use of auditors and other external
experts using targeted risk based reporting.
12. In 2006 the global CEOs of the six largest
audit networks including Ernst & Young published a vision
paper1 which explored many of these issues. It highlighted increasing
globalisation and the growth of emerging markets. It recognised
that auditors could only contribute to the stability and strength
of capital markets in this new world if corporate reporting and
auditing standards were global; if independent audit oversight
bodies became more formally coordinated; and if the large audit
networks continued to improve the consistency of audits across
the different countries in which they operate. This included enabling
audit networks to integrate more closely. We continue to believe
these are essential drivers of audit quality.
13. In the UK alone, policy initiatives
are already underway in relation to many of these issues. Ernst
& Young is pleased to be actively involved in all of these
debates. We recognise the vital importance of ensuring there is
a robust framework for corporate governance, corporate reporting
and auditing that meets the developing needs and expectations
of our stakeholders.
27 September 2010
APPENDIX
RESPONSES TO SPECIFIC QUESTIONS
For more information about our organisation,
please refer to our UK transparency report.[4]
It provides insights relevant to the Committee's specific questions.
Why did auditing become so concentrated on four
global firms? For example, do economies of scale make it too difficult
for smaller firms to compete?
1. Concentration through consolidation has
been driven mostly by the staggering growth in number, size and
reach of multinational companies, the need for scale to build
effective global networks to audit these companies, increasing
litigation risk and the demise of Andersen in 2002. A 2006 Oxera
report on competition and choice in the UK audit market[5]
provides more detail.
2. The audit market for large listed companies
in the UK is concentrated among the Big 4 audit firms. Outside
this, the UK audit market is much less concentrated. As at September
2010 Ernst & Young's share of FTSE350 audits stands at 17.4%
(61 audits). Our share of FTSE100 audits stands at 18 audits.
3. Only the very largest global companies
require the geographic reach and industry specialisation of the
Big 4. However, there is a widespread misconception that only
the Big 4 networks have the depth and reach to participate in
the market for listed company audits. As we have consistently
said, we are in favour of promoting the capability of audit firms
outside the Big 4 through market-based rather than regulatory
initiatives
4. By way of a specific example, the six
largest global audit networks including Ernst & Young recently
wrote to the OECD arguing for the removal of Big 4 only clauses
in loan agreements. We do recognise though, that in the short
to medium term, it will be difficult for audit firms who do not
already have the capability to enter the market for large listed
companies for a number of market-driven reasons including: (i)
significant investment required for market entry; (ii) the long
investment horizon; (iii) liability risks; and (iv) audit client
inertia.
Does a lack of competition mean clients are charged
excessive fees?
5. No. The largest audit firms are extremely
competitive. Auditors are subject to reappointment by management
and the shareholders every year, during which process audit fees
are negotiated. The company can choose to switch auditor if satisfactory
terms cannot be agreed.
6. Listed companies also run competitive
tenders for both audit and non-audit services. However, companies
do not change their auditor very often because running tenders
and changing auditors is costly. It takes time for auditors to
build up knowledge of the company and to form strong relationships
with the audit committee, both essential factors in ensuring audit
quality. When audit tendering does occur it is highly competitive,
and the incumbent is typically retained in only a third of cases.
Does a narrow field of competition affect objectivity
of advice provided?
Alternatively, does limited competition make it
easier for auditors to provide unwelcome advice to clients who
have relatively few choices as there is less scope to take their
business elsewhere?
7. We do not accept the premise that there
is limited competition. In any event, in our experience, concentration
in the UK audit market is not linked to the objectivity of advice.
Objectivity is driven by personal qualities, reputation, professional
training, industry codes of ethics, ethical and independence standards,
auditing standards, and continuing professional development; not
to mention positive reinforcement in the workplace, including
tone from the top. At Ernst & Young these drivers are supported
by a detailed system of internal quality control.[6]
8. The UK is also recognised as a global
leader in the regulation and oversight of the audit profession.
The drivers of objectivity are reinforced by independent oversight,
disciplinary schemes, and potential civil and criminal liabilities.
9. Ernst & Young's client acceptance
and continuance policy establishes a rigorous process for determining
whether to accept a new client or continue with an existing relationship.
This policy is fundamental to maintaining quality, managing risk,
protecting our people and meeting regulatory requirements. A company's
propensity to "opinion shop" or to exert unreasonable
pressure on its auditors is a highly relevant factor to client
acceptance and continuance.
10. Auditors and accountants are highly
regulated; ethics is integral to the sector and ingrained in its
qualifications and working practices. At Ernst & Young, our
culture of ethics and integrity is embedded in our training programmes
and internal communications. As part of our approach to professional
values, our employees are expected to follow a strict Code of
Conduct.
11. The requirement to maintain independence
and objectivity is one of Ernst & Young's ten principles of
quality and risk management which apply globally across our organisation
and against which our people are evaluated and rewarded.
What is the role of auditors and should it be
changed?
12. Auditors play an essential role in the
functioning of the global capital markets and add value to the
roles played by other stakeholders such as preparers, investors
and regulators. We are committed to promoting and enhancing transparency
to instil confidence in financial markets. Transparent financial
information facilitates the allocation of capital to its highest
and best uses, which in turn drives economic growth and rising
standards of living.
13. Financial statements are prepared by
companies and the accounting judgments are the responsibility
of management and the directors. They are a snapshot of a company's
financial health at a particular point in time. A statutory audit
is an examination of a company's financial statements carried
out in accordance with independently prescribed auditing standards.
After the audit is completed, the auditor issues an audit opinion
which is published as part of the financial statements. It states
whether or not the financial statements show a true and fair view
of the company's business operations and financial health during
the period covered. It is designed to provide reasonable (not
absolute) assurance that the company's financial statements are
free from material misstatement.
14. Except for the going concern statement,
the audit does not provide any assurance about a company's future
performance because financial statements are backward-looking.
15. Independent assurance of that information
by the external auditor builds trust among stakeholders that the
information can be relied on, thereby instilling investor confidence.
Independent research, recently published by Maastricht Accounting,
Auditing and Information Management Research Center (MARC)[7]
provides strong support for this.
16. We believe the current reporting model
delivers significant value to those who use it. However, the audit
profession and other market participants need to reflect on the
crisis and challenge the status quo. Working with professional
bodies, regulators, investor groups and the audit profession,
we have been developing our thinking on how corporate reporting
and audit for all companies may be enhanced. Our views are as
follows:
(a) There is a need to increase awareness of
how auditors discharge their professional responsibilities.
(b) A coherent framework needs to be developed
to enable listed companies to provide high quality disclosures
that provide a fuller picture of their financial position and
future viability. This would include better (not necessarily more)
information about business models and the risks to it; internal
controls; and management judgements and estimates. Such enhanced
reporting will likely also require assurance.
(c) The key objective should be specific reporting
which avoids boilerplate language. New disclosures by companies
about their business should be meaningful and auditors should
provide assurance statements which provide better information
about what the auditor has done. Unfortunately liability risks
present challenges to the objective. Safe harbours for management,
audit committees and auditors should be explored.
(d) To maximise the benefit for all stakeholders,
these improvements need to take place within an internationally
consistent framework which includes a single set of high quality
global accounting standards.
Were auditors sufficiently sceptical when auditing
banks in the run-up to the financial crisis of 2008? If not, was
the lack of competition in auditing a contributory factor?
17. While Ernst & Young audits many
banks outside the UK, we did not audit any of the major UK headquartered
banks during the crisis. Our UK perspective on this question is
therefore limited by this fact.
18. A challenging mindset is a key driver
of audit quality. Accordingly, the application of professional
scepticism is a fundamental auditing requirement. It is important
that we have an open discussion about the concept because it will
enhance stakeholder understanding of and confidence in the auditor's
work. We therefore welcome the Auditing Practices Board's paper
on the topic.[8]
19. Concerns about professional scepticism
in the audit of banks have been raised by the FSA in its joint
Discussion Paper with the FRC[9]
and more generally by the Audit Inspection Unit of the Professional
Oversight Board (AIU) in its latest round of reporting. We have
seen no evidence which suggests there is a pervasive lack of scepticism
in the audit profession. Moreover, as shown by successive AIU
reports the fact remains that the quality of listed company audits
in the UK is good. We recognise that improvements can always be
made and Ernst & Young continues to make significant investments
in training and processes to achieve this.
20. There is also room for new and alternative
ways for auditors to better demonstrate the application of scepticism
to investors and regulators. In this regard, we believe that a
professional judgment framework for preparers and auditors, which
encourages a critical, reasoned, rigorous, thoughtful and deliberate
approach to decision-making, would strengthen financial reporting
and audit quality and contribute to the exercise and demonstration
of professional scepticism.
21. We do not believe that audit market
concentration has any impact on professional scepticism. The key
drivers of objectivity and professional scepticism, including
the significant reputational, regulatory and financial risks for
auditors, exist regardless of the number of market players.
What, if anything, could auditors have done to
mitigate the banking crisis? How can auditors contribute to better
supervision of banks?
22. We support the Committee's findings
from its 2nd Report of Session 2008-09:
"We have seen no evidence that bank auditors
failed in their statutory duty to make a going-concern judgement
on their clients. Bank auditors should not be required to make
a more general judgement on the quality of their clients' strategies.
In any event, it is unlikely that auditors would be more able
than financial supervisors to identify structural problems in
the financial sector".[10]
23. Audits are focused on individual entities.
However, the risks giving rise to the financial crisis were market-wide
and not confined to a single entity or geography. Accounting standards
and the audit profession played an important role in bringing
some realities of the banking crisis into sight quickly. Although
painful, this enabled investors, management, creditors and policymakers
to recognise problems or opportunities on a timely basis so they
could make informed decisions and take appropriate corrective
actions.
24. The financial crisis presents all stakeholders
with an opportunity for positive change. In this regard, auditors
and prudential supervisors are examining how auditors might contribute
to better supervision of banks. In June 2010, the ICAEW published
its report on how the audits of banks might be enhanced.[11]
It provides a good explanation of how auditors might contribute
to better bank supervision. We support its recommendations including
the increased use of section 166 reports and increased interactions
between prudential supervisors and auditors. On 29 June 2010 the
FSA and FRC published a Discussion Paper on the topic.[12]
If the Committee would like a copy of our response, please let
us know.
25. The six largest UK audit firms have
recently joined a working group comprising representatives from
the FSA, FRC, ICAEW and chaired by the Bank of England. Its purpose
is to consider how the relationship between auditors, firms and
regulators can be more clearly defined to permit more useful and
comparable disclosures about judgment issues and the sensitivities
around material valuations. The working group will also seek to
define ways in which the relationship between auditors and prudential
regulators can be enhanced in practical terms.
How much information should bank auditors share
with the supervisory authorities and vice versa?
26. Regular exchange of information between
auditors and bank supervisors enables both parties to perform
their duties more efficiently and effectively. We therefore welcome
the FSA's new consultative approach and the recent improvements
in both the frequency and quality of dialogue. Ernst & Young
now meets with the FSA and the other five large audit networks
on a regular basis. This year the FSA has sought meetings with
us on a bi-lateral basis every six months. We meet with individual
supervisors about certain individual institutions around twice
a year.
27. There is still room for significant
further improvement. In particular, discussions between the FSA
and auditors must be a two-way process for sharing as much information
as possible. This includes information about individual entities
and market-wide information held by prudential regulators. In
the short term, the FSA needs to find ways within its legal constraints
to notify auditors of relevant concerns, with a review of the
current legal constraints in the long term.
28. Tri-lateral engagement (FSA, auditor,
financial institution) is equally important. The FSA should also
increase its interactions with audit committees.
If need be, how could incentives to provide objective
and, in some cases unwelcome, advice to clients be strengthened?
29. The existing drivers of objectivity
explained in paragraph 7 of this Appendix provide a good platform
for the provision of objective advice to clients. In many ways
the most important driver of objectivity is talented professionals.
For this reason, regulators need to help ensure that the audit
profession continues to be able to attract and retain talented
individuals with the requisite diversity of skills.
Do conflicts of interest arise between audit and
consultancy roles? If so, how should they be avoided or mitigated?
30. Conflicts of interests, which can arise
between the provision of audit and non-audit services to the same
client, are just one of a number of potential threats to auditor
independence. The UK regulatory regime adopts a "threats
and safeguards approach". This provides that such threats
can be managed by audit committee oversight, transparency, the
implementation of safeguards and in some cases prohibitions.
31. Responses to a recent APB consultation
indicate that there continues to be widespread stakeholder confidence
in this approach.[13]
32. Audit firms operate in a highly regulated
environment with strong independence requirements both for audit
firms and individual auditors, who also subscribe to robust ethical
codes. Audit firms also have to operate a strong system of independence
controls and are subject to significant independent oversight.
That said, we accept there can be situations where it would be
inappropriate to provide certain non-audit services to an audit
client.
33. Greater transparency about the nature
and amount of non-audit services auditors provided to audit clients
should address any remaining perceptions among some stakeholders
that objectivity and independence is impaired by their provision.
We seek to achieve this through our transparency report, as well
as statutory public disclosures, which outline revenues attributable
to different segments of our firm. This information provides companies
and investors with the relative size of the non-audit practice
as compared to the audit practice.
34. There also needs to be better disclosure
in company annual reports of the audit committee's policy on non-audit
services together with clearer information of how non-audit services
are categorised (many non-audit services are actually integral
to the audit) plus additional guidance for audit committees. In
2010, we were pleased to assist the Institute of Chartered Accountants
of Scotland to develop recommendations[14]
for the FRC and the Department for Business on this issue.
35. It is worth noting that the majority
of our non-audit services are provided to non-audit clients. They
made up 62.4% of our UK revenue for the financial year ended 2
July 2010 as opposed to 13.4% of total UK revenues for non-audit
services provided to audit clients. Assurance services for audit
clients made up the remaining 24.2%.
36. Auditors at multi-disciplinary firms
can further increase their business acumen and technical skills
by working at non-audit clients. The opportunity to develop multi-disciplinary
skills encourages the recruitment and retention of high quality
professionals; an essential component in audit quality.
Should more competition be introduced into auditing?
If so, how?
37. The terms audit concentration, audit
competition and choice are sometimes used interchangeably when
they refer to different issues. Audit concentration is a small
number of audit firms, such as the Big 4, performing audits for
one particular market (eg FTSE100); audit choice means the number
of audit firms available for companies to choose; and competition
refers to a fair contest for market share among any number of
audit firms.
38. A robust, competitive, listed company
audit market positively impacts on audit quality and innovation.
It is therefore in the best interests of investors and the capital
markets.
39. There continues to be healthy competition
in the audit market but we recognise that there could be greater
choice. We therefore welcome sensible efforts to increase choice
in the listed company audit market and support recommendations
that might help to increase choice without compromising audit
quality. Regulators and other capital market participants should
encourage market-based initiatives to encourage auditor choice
of the kind identified by the FRC's Market Participants Group.[15]
Imposing solutions that are not market-based are likely to lead
to unintended consequences.
40. The risk of catastrophic liability for
auditors of large listed companies can serve as a barrier to entry
for some of the smaller audit firms. Catastrophic liability itself
could create further consolidation in the larger listed company
audit market. Policymakers need to take steps to ensure that choice
is not further eroded by the disappearance of one of the remaining
audit networks.
Should the role of internal auditors be enhanced
and how should they interact with external auditors?
41. Consistent with our view that policymakers
need to examine the governance framework holistically, options
for enhancing the role of internal audit should also be investigated.
This is particularly relevant in financial institutions where
failures in organisation-wide risk management were a key factor
contributing to the crisis. In this respect, we support the prevailing
FSA view that internal audit in financial institutions should
focus on systems of governance, risk management and internal controls.
We would support stronger reporting lines by the Head of Internal
Audit to the Audit Committee Chair with a dotted line to the CEO/CFO
rather than the CRO. There is also a need for internal audit to
shed its traditional image as a monitoring role. It should be
seen as a function that rigorously audits an organisation's policies
and processes to ensure they are properly implemented and effective.
42. Internal and external audit serve different
purposes. They have different responsibilities, different accountabilities
and are independent of each other. Nevertheless the roles are
complementary at times. It is important they are aligned when
planning their respective work to avoid duplication of effort
and to maximise the total assurance that they provide.
Should the role of audit committees be enhanced?
43. Yes, this is extremely important. High
quality reporting requires audit committees, as representatives
of shareholders, to be strong, dedicated and thoroughly engaged.
44. Audit committees could be strengthened
by looking at: (i) their composition; (ii) their experience, skills
and training; (iii) their resources; (iv) greater audit committee
accountability for the selection and oversight of auditors; (v)
better audit committee reporting about the financial reporting
process; (vi) more regular meetings between audit committees,
boards and auditors; (vii) auditors reporting to the shareholders'
meeting; and (viii) better engagement between investors and audit
committees.
45. Enhancing the audit committee's role
will help reinforce auditor independence and support the auditor
in exercising professional scepticism. Stronger audit committees
will be better placed to challenge management, auditors and their
respective judgements. Such strengthening will make them better
equipped to support the auditor in their dealings with management.
Is the auditing profession well placed to promote
improvement in corporate governance?
46. Yes. By way of an example, Ernst &
Young has extensive financial reporting and corporate governance
knowledge and experience, gained across all markets and geographies.
In order to promote best practice in corporate governance, in
the UK we operate programmes such as the Independent Director
Programme and the Audit Committee Chair Forum. Internationally,
Ernst & Young convenes a series of audit committee leadership
networks in conjunction with Tapestry.[16]
Their purpose is to promote positive change in corporate governance,
improving the performance of audit committees and enhancing trust
in financial markets.
47. We also believe firms like Ernst &
Young have an opportunity to be exemplars of good governance.
Strong governance has been fundamental to the integration of our
organisation and to strengthening our ability to provide consistent,
high quality service worldwide. In recent years we have embraced
many changes to audit firm governance such as independent regulation
and the separation of management and governance functions.
48. In January 2010, the FRC and ICAEW issued
the Audit Firm Governance Code. Its purpose, whose origins preceded
the financial crisis, is to promote confidence and choice in the
UK audit market and provide a benchmark of good governance.
49. At Ernst & Young, we see the publication
of the Code as a real opportunity. Over the past few years, we
have moved to integrate our organisation and strengthen our ability
to provide quality audits. For us, much of our ability to do this
depends on strong governance and tone from the top. For these
reasons, for the first time we will appoint independent non-executive
representatives will join our organisation. They will join our
Global Advisory Council, the highest global governance body in
the Ernst & Young organisation. Their role will be to advise
on the public interest aspects of our organisation's decision
making, risk management and stakeholder dialogue.
4 http://www.ey.com/uk/en/About-us/About-EY-Transparency-Report Back
5
http://www.oxera.com/cmsDocuments/Reports/DTI%20Auditors.pdf Back
6
More details of this system are contained in our transparency
report at http://www.ey.com/uk/en/About-us/About-EY-Transparency-Report Back
7
http://www.maastrichtuniversity.nl/web/main/sitewide/News1/NewsReportFormMARCValueOfAudit.htm Back
8
http://www.frc.org.uk/apb/publications/pub2343.html Back
9
http://www.fsa.gov.uk/pubs/discussion/dp10_03.pdf Back
10
http://www.publications.partliament.uk/pa/ld200809/ldselect/ldconaf/101/101i/pdf
para 211 Back
11
http://alturl.com/jgref Back
12
http://www.fsa.gov.uk/pubs/discussion/dp10_03.pdf Back
13
http://www.frc.org.uk/images/uploaded/documents/consultation&20provision%20of%20non-audit%20services%20by%20auditors2.pdf
page 10 Back
14
http://www.icas.org.uk/site/cms/download/AA/2010/WG_Report_Non_Audit_Services_January_2010.pdf Back
15
http://www.frc.org.uk/documents/pagemanager/frc/FRCMPG%20Final%20Report%20for%20web.pdf Back
16
For more information go to: http://www.tapestrynetworks.com/networks/net_audit.html Back
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