In re Beutel Accountancy Corporation

                                                 UNITED                                                 STATES OF AMERICA 

                                                                     Before                                                                     the

                                    SECURITIES            AND            EXCHANGE COMMISSION 

SECURITIES EXCHANGE ACT OF 1934 
Release No. 56401 / September 13, 2007 
ACCOUNTING AND AUDITING ENFORCEMENT 
Release No. 2681 / September 13, 2007 
ADMINISTRATIVE PROCEEDING 
File No. 3-12762 
In the Matter of 
Beutel Accountancy Corporation 
and Todd W. Beutel, CPA, 
Respondents. 
ORDER INSTITUTING PUBLIC 
ADMINISTRATIVE AND CEASE-AND-
DESIST PROCEEDINGS PURSUANT TO 
SECTIONS 4C AND 21C OF THE 
SECURITIES EXCHANGE ACT OF 1934 
AND RULE 102(e) OF THE 
COMMISSION’S RULES OF PRACTICE, 
MAKING FINDINGS, AND IMPOSING 
REMEDIAL SANCTIONS AND A 
CEASE-AND-DESIST ORDER 
I.                                                                             
The Securities and Exchange Commission (“Commission”) deems it appropriate that 
cease-and-desist proceedings be, and hereby are, instituted against Beutel Accountancy 
Corporation and Todd W. Beutel, CPA (collectively “Respondents”) pursuant to Section 21C of 
the Securities Exchange Act of 1934 (“Exchange Act”) and that public administrative 
proceedings be, and hereby are, instituted against Beutel Accountancy Corporation pursuant to 
Section 4C
1
 of the Exchange Act and Rule 102(e)(1)(iii) of the Commission’s Rules of Practice.
2 
1 
Section 4C provides, in relevant part, that: 
The  Commission  may  censure  any  person,  or  deny,  temporarily  or  permanently,  
to  any  person  the  privilege  of  appearing  or  practicing  before  the  Commission  in  
any way, if that person is found . . . to have willfully violated, or willfully aided 
and abetted the violation of, any provision of the securities laws or the rules and 
regulations thereunder. 
2 
Rule 102(e)(1)(iii) provides, in relevant part, that: 

                                                                            II.                                                                            
In anticipation of the institution of these proceedings, Respondents have submitted an 
Offer of Settlement (“Offer”) which the Commission has determined to accept.  Solely for the 
purpose of these proceedings and any other proceedings brought by or on behalf of the 
Commission, or to which the Commission is a party, and without admitting or denying the 
findings herein, except as to the Commission’s jurisdiction over them and the subject matter of 
these proceedings, which are admitted, Respondents consent to the entry of this Order Instituting 
Public Administrative and Cease-and-Desist Proceedings Pursuant to Sections 4C and 21C of the 
Securities Exchange Act of 1934 and Rule 102(e) of the Commission’s Rules of Practice, 
Making Findings, and Imposing Remedial Sanctions and a Cease-and-Desist Order (“Order”), as 
set forth below. 
III. 
On the basis of this Order and Respondents’ Offer, the Commission finds
3
 that: 
A.        RESPONDENTS        
1. Beutel Accountancy Corporation (the “Firm”) is a California corporation and a 
public accounting firm headquartered in Agoura Hills, California.  The Firm audited Vital Health 
Technologies, Inc.’s (also known as Caribbean American Health Resorts, Inc.) financial 
statements for the company’s 2003 and 2004 fiscal years ended December 31, 2003, and 
December 31, 2004, respectively.  Vital Health Technologies, Inc. dismissed the Firm as its 
independent auditor on May 20, 2005. 
2. Todd W. Beutel, CPA (“Beutel”), age 42, is a certified public accountant 
licensed in the state of California since 1995.  Beutel was the engagement partner in connection 
with the Firm’s audit of Vital Health Technologies, Inc.’s financial statements for the company’s 
2003 and 2004 fiscal years ended December 31, 2003, and December 31, 2004, respectively.  
B.        FACTS        
1. Vital Health Technologies, Inc. (“Vital Health”) is a Minnesota corporation with 
its headquarters in Beverly Hills, California. Vital Health’s common stock is quoted on the Pink 
Sheets under the symbol “CAHR” and is registered with the Commission pursuant to Section 
12(g) of the Exchange Act. For fiscal year ended December 31, 2003, Vital Health reported 
revenues of $10,500, and total assets of $1 million.  For fiscal year ended December 31, 2004, 
The Commission may censure a person or deny, temporarily or permanently, the 
privilege  of  appearing  or  practicing  before  it  in  any  way  to  any  person  who  is  
found . . . to have willfully violated, or willfully aided and abetted the violation of 
any   provision   of   the   Federal   securities   laws   or   the   rules   and   regulations   
thereunder. 
The findings herein are made pursuant to Respondents’ Offer of Settlement and are not 
binding on any other person or entity in this or any other proceeding. 
2

3 

Vital Health reported revenues of $5,500, and total assets of $1 million. 
2. Vital Health has at all relevant times been an issuer as defined by the Sarbanes-
Oxley Act of 2002 (the “Act”). 
3. The Firm audited Vital Health’s 2003 financial statements included in Vital 
Health’s annual report for fiscal year 2003 on Form 10-KSB, filed with the Commission on April 
14, 2004. As part of that audit, the Firm prepared and issued an audit report dated March 29, 
2004, which the company included in its 2003 Form 10-KSB.   
4. The Firm audited Vital Health’s 2004 financial statements included in Vital 
Health’s annual report for fiscal year 2004 on Form 10-KSB, filed with the Commission on April 
15, 2005. As part of that audit, the Firm prepared and issued an audit report dated April 14, 2005 
(together with the March 29, 2004 audit report, the “Vital Health audit reports”), which the 
company included in its 2004 Form 10-KSB.  Vital Health paid the Firm a total of $22,000 for 
the 2003 and 2004 audit work.
4 
5. At the time the Firm issued the Vital Health audit reports, it was not registered 
with the Public Company Accounting Oversight Board (the “Board”), as required by Section 
102(a) of the Act. 
6. Beutel was the engagement partner on the Firm’s audits of Vital Health’s 2003 
and 2004 financial statements.  Beutel participated in the preparation and issuance of the Vital 
Health audit reports. 
7. By public notice of disapproval dated July 28, 2005, effective as of May 10, 2005, 
the Board disapproved an application for registration submitted by the Firm based in part on the 
Firm’s violation of Section 102(a) of the Act in issuing the Vital Health audit reports.
5 
C. VIOLATIONS 
1. Section 102(a) of the Act provides that “it shall be unlawful for any person that is 
not a registered public accounting firm to prepare or issue, or to participate in the preparation or 
issuance of, any audit report with respect to any issuer.”
6 
4 
During the course of the Commission’s investigation, the Firm voluntarily reimbursed 
Vital Health the $22,000 in audit fees.  In view of the Firm’s reimbursement, the Commission is 
not ordering disgorgement in this matter. 
5 
PCAOB Release No. 2005-017 (July 28, 2005). The public notice of disapproval also 
found that the Firm’s issuance of the Vital Health audit reports violated Board Rule 2100, which 
implemented Section 102(a) of the Act.  Id. 
6 
A violation of the Act or any rule that the Board issues under the Act is treated for all 
purposes in the same manner as a violation of the Exchange Act, including with respect to 
penalties. Sarbanes-Oxley Act of 2002, 15 U.S.C.A. § 7202(b)(1) (West 2002). 
3


2. The provisions of Section 102(a) of the Act became effective on October 22, 
2003.
7 
3. Based on the conduct described above, the Firm willfully
8
 violated Section 102(a) 
of the Act. 
4. Based on the conduct described above, Beutel caused the Firm’s violation of 
Section 102(a) of the Act. 
D.        FINDINGS        
Based on the foregoing, the Commission finds that the Firm willfully violated Section 
102(a) of the Sarbanes-Oxley Act of 2002, and that Beutel caused the Firm’s violation of Section 
102(a) of the Act. 
E. UNDERTAKINGS 
Respondents undertake not to request, demand, or accept, directly or indirectly, any 
compensation from Vital Health in connection with the audit work associated with the Vital 
Health audit reports.  In determining whether to accept the Offer, the Commission has considered 
this undertaking. 
IV. 
In view of the foregoing, the Commission deems it appropriate to impose the sanctions 
agreed to in Respondents’ Offer. 
Accordingly, it is hereby ORDERED, effective immediately, that: 
1. Beutel Accountancy Corporation  
A. The Firm shall cease and desist from committing or causing any violations 
and any future violations of Section 102(a) of the Act. 
B. The Firm is censured. 
7 
Section 102(a) became effective “[b]eginning 180 days after the date of the determination 
of the Commission under Section 101(d)” of the Act that the Board was prepared to undertake its 
statutory responsibilities. The Commission made the required determination on April 25, 2003.  
See
 Order Regarding Section 101(d) of the Sarbanes-Oxley Act of 2002, Securities Act Release 
No. 8223, Exchange Act Release No. 47746, 2003 WL 1956164  (Apr. 25, 2003). 
8 
“Willfully” as used in this Offer means intentionally committing the act that constitutes 
the violation. There is no requirement that the actor also be aware that he is violating a rule or 
statute.  See
 Wonsover v. SEC, 205 F.3d 408, 414 (D.C. Cir. 2000); Tager v. SEC, 344 F.2d 5, 8 
(2d Cir. 1965). 
4


C. The Firm may practice before the Commission as an independent accountant 
provided that: 
1. It is registered with the Board in accordance with the Act, and such 
registration continues to be effective; and 
2. It has submitted to the Commission staff (attention: Office of the 
Chief Accountant) the Board’s letter notifying the Firm that its registration application has been 
approved. 
2. Todd W. Beutel, CPA  
A. Beutel shall cease and desist from committing or causing any violations and 
any future violations of Section 102(a) of the Act. 
B. Beutel may practice before the Commission as an independent accountant 
provided that: 
1. The public accounting firm with which he is associated is 
registered with the Board in accordance with the Act, and such registration continues to be 
effective; and 
2. He has submitted to the Commission staff (attention: Office of the 
Chief Accountant) the Board’s letter notifying the public accounting firm with which he is 
associated that its registration application has been approved. 
By the Commission. 
       Nancy M. Morris
       Secretary 
5

UNITED STATES OF AMERICA 

 Before the

   SECURITIES AND EXCHANGE COMMISSION 


SECURITIES EXCHANGE ACT OF 1934 
Release No. 56401 / September 13, 2007 

ACCOUNTING AND AUDITING ENFORCEMENT 
Release No. 2681 / September 13, 2007 

ADMINISTRATIVE PROCEEDING 
File No. 3-12762 

In the Matter of 

Beutel Accountancy Corporation 
and Todd W. Beutel, CPA, 

Respondents. 

ORDER INSTITUTING PUBLIC 
ADMINISTRATIVE AND CEASE-AND
DESIST PROCEEDINGS PURSUANT TO 
SECTIONS 4C AND 21C OF THE 
SECURITIES EXCHANGE ACT OF 1934 
AND RULE 102(e) OF THE 
COMMISSION’S RULES OF PRACTICE, 
MAKING FINDINGS, AND IMPOSING 
REMEDIAL SANCTIONS AND A 
CEASE-AND-DESIST ORDER 

I. 

The Securities and Exchange Commission (“Commission”) deems it appropriate that 
cease-and-desist proceedings be, and hereby are, instituted against Beutel Accountancy 
Corporation and Todd W. Beutel, CPA (collectively “Respondents”) pursuant to Section 21C of 
the Securities Exchange Act of 1934 (“Exchange Act”) and that public administrative 
proceedings be, and hereby are, instituted against Beutel Accountancy Corporation pursuant to 
Section 4C1 of the Exchange Act and Rule 102(e)(1)(iii) of the Commission’s Rules of Practice.2 

1 Section 4C provides, in relevant part, that: 

The Commission may censure any person, or deny, temporarily or permanently, 
to any person the privilege of appearing or practicing before the Commission in 
any way, if that person is found . . . to have willfully violated, or willfully aided 
and abetted the violation of, any provision of the securities laws or the rules and 
regulations thereunder. 

2 Rule 102(e)(1)(iii) provides, in relevant part, that: 



 II. 

In anticipation of the institution of these proceedings, Respondents have submitted an 
Offer of Settlement (“Offer”) which the Commission has determined to accept.  Solely for the 
purpose of these proceedings and any other proceedings brought by or on behalf of the 
Commission, or to which the Commission is a party, and without admitting or denying the 
findings herein, except as to the Commission’s jurisdiction over them and the subject matter of 
these proceedings, which are admitted, Respondents consent to the entry of this Order Instituting 
Public Administrative and Cease-and-Desist Proceedings Pursuant to Sections 4C and 21C of the 
Securities Exchange Act of 1934 and Rule 102(e) of the Commission’s Rules of Practice, 
Making Findings, and Imposing Remedial Sanctions and a Cease-and-Desist Order (“Order”), as 
set forth below. 

III. 

On the basis of this Order and Respondents’ Offer, the Commission finds3 that: 

A. RESPONDENTS 

1. Beutel Accountancy Corporation (the “Firm”) is a California corporation and a 
public accounting firm headquartered in Agoura Hills, California.  The Firm audited Vital Health 
Technologies, Inc.’s (also known as Caribbean American Health Resorts, Inc.) financial 
statements for the company’s 2003 and 2004 fiscal years ended December 31, 2003, and 
December 31, 2004, respectively.  Vital Health Technologies, Inc. dismissed the Firm as its 
independent auditor on May 20, 2005. 

2. Todd W. Beutel, CPA (“Beutel”), age 42, is a certified public accountant 
licensed in the state of California since 1995.  Beutel was the engagement partner in connection 
with the Firm’s audit of Vital Health Technologies, Inc.’s financial statements for the company’s 
2003 and 2004 fiscal years ended December 31, 2003, and December 31, 2004, respectively.  

B. FACTS 

1. Vital Health Technologies, Inc. (“Vital Health”) is a Minnesota corporation with 
its headquarters in Beverly Hills, California. Vital Health’s common stock is quoted on the Pink 
Sheets under the symbol “CAHR” and is registered with the Commission pursuant to Section 
12(g) of the Exchange Act. For fiscal year ended December 31, 2003, Vital Health reported 
revenues of $10,500, and total assets of $1 million.  For fiscal year ended December 31, 2004, 

The Commission may censure a person or deny, temporarily or permanently, the 
privilege of appearing or practicing before it in any way to any person who is 
found . . . to have willfully violated, or willfully aided and abetted the violation of 
any provision of the Federal securities laws or the rules and regulations 
thereunder. 

The findings herein are made pursuant to Respondents’ Offer of Settlement and are not 
binding on any other person or entity in this or any other proceeding. 

2


3 



Vital Health reported revenues of $5,500, and total assets of $1 million. 

2. Vital Health has at all relevant times been an issuer as defined by the Sarbanes-
Oxley Act of 2002 (the “Act”). 

3. The Firm audited Vital Health’s 2003 financial statements included in Vital 
Health’s annual report for fiscal year 2003 on Form 10-KSB, filed with the Commission on April 
14, 2004. As part of that audit, the Firm prepared and issued an audit report dated March 29, 
2004, which the company included in its 2003 Form 10-KSB.   

4. The Firm audited Vital Health’s 2004 financial statements included in Vital 
Health’s annual report for fiscal year 2004 on Form 10-KSB, filed with the Commission on April 
15, 2005. As part of that audit, the Firm prepared and issued an audit report dated April 14, 2005 
(together with the March 29, 2004 audit report, the “Vital Health audit reports”), which the 
company included in its 2004 Form 10-KSB.  Vital Health paid the Firm a total of $22,000 for 
the 2003 and 2004 audit work.4 

5. At the time the Firm issued the Vital Health audit reports, it was not registered 
with the Public Company Accounting Oversight Board (the “Board”), as required by Section 
102(a) of the Act. 

6. Beutel was the engagement partner on the Firm’s audits of Vital Health’s 2003 
and 2004 financial statements.  Beutel participated in the preparation and issuance of the Vital 
Health audit reports. 

7. By public notice of disapproval dated July 28, 2005, effective as of May 10, 2005, 
the Board disapproved an application for registration submitted by the Firm based in part on the 
Firm’s violation of Section 102(a) of the Act in issuing the Vital Health audit reports.5 

C. VIOLATIONS 

1. Section 102(a) of the Act provides that “it shall be unlawful for any person that is 
not a registered public accounting firm to prepare or issue, or to participate in the preparation or 
issuance of, any audit report with respect to any issuer.”6 

4 During the course of the Commission’s investigation, the Firm voluntarily reimbursed 
Vital Health the $22,000 in audit fees.  In view of the Firm’s reimbursement, the Commission is 
not ordering disgorgement in this matter. 

5 PCAOB Release No. 2005-017 (July 28, 2005). The public notice of disapproval also 
found that the Firm’s issuance of the Vital Health audit reports violated Board Rule 2100, which 
implemented Section 102(a) of the Act.  Id. 

6 A violation of the Act or any rule that the Board issues under the Act is treated for all 
purposes in the same manner as a violation of the Exchange Act, including with respect to 
penalties. Sarbanes-Oxley Act of 2002, 15 U.S.C.A. § 7202(b)(1) (West 2002). 

3




2. The provisions of Section 102(a) of the Act became effective on October 22, 
2003.7 

3. Based on the conduct described above, the Firm willfully8 violated Section 102(a) 
of the Act. 

4. Based on the conduct described above, Beutel caused the Firm’s violation of 
Section 102(a) of the Act. 

D. FINDINGS 

Based on the foregoing, the Commission finds that the Firm willfully violated Section 
102(a) of the Sarbanes-Oxley Act of 2002, and that Beutel caused the Firm’s violation of Section 
102(a) of the Act. 

E. UNDERTAKINGS 

Respondents undertake not to request, demand, or accept, directly or indirectly, any 
compensation from Vital Health in connection with the audit work associated with the Vital 
Health audit reports.  In determining whether to accept the Offer, the Commission has considered 
this undertaking. 

IV. 

In view of the foregoing, the Commission deems it appropriate to impose the sanctions 
agreed to in Respondents’ Offer. 

Accordingly, it is hereby ORDERED, effective immediately, that: 

1. Beutel Accountancy Corporation  

A. The Firm shall cease and desist from committing or causing any violations 
and any future violations of Section 102(a) of the Act. 

B. The Firm is censured. 

7 Section 102(a) became effective “[b]eginning 180 days after the date of the determination 
of the Commission under Section 101(d)” of the Act that the Board was prepared to undertake its 
statutory responsibilities. The Commission made the required determination on April 25, 2003.  
See Order Regarding Section 101(d) of the Sarbanes-Oxley Act of 2002, Securities Act Release 
No. 8223, Exchange Act Release No. 47746, 2003 WL 1956164  (Apr. 25, 2003). 

8 “Willfully” as used in this Offer means intentionally committing the act that constitutes 
the violation. There is no requirement that the actor also be aware that he is violating a rule or 
statute.  See Wonsover v. SEC, 205 F.3d 408, 414 (D.C. Cir. 2000); Tager v. SEC, 344 F.2d 5, 8 
(2d Cir. 1965). 

4




C. The Firm may practice before the Commission as an independent accountant 
provided that: 

1. It is registered with the Board in accordance with the Act, and such 
registration continues to be effective; and 

2. It has submitted to the Commission staff (attention: Office of the 
Chief Accountant) the Board’s letter notifying the Firm that its registration application has been 
approved. 

2. Todd W. Beutel, CPA  

A. Beutel shall cease and desist from committing or causing any violations and 
any future violations of Section 102(a) of the Act. 

B. Beutel may practice before the Commission as an independent accountant 
provided that: 

1. The public accounting firm with which he is associated is 
registered with the Board in accordance with the Act, and such registration continues to be 
effective; and 

2. He has submitted to the Commission staff (attention: Office of the 
Chief Accountant) the Board’s letter notifying the public accounting firm with which he is 
associated that its registration application has been approved. 

By the Commission. 

       Nancy  M.  Morris
       Secretary  

5