SEC Press pdf 44 KB 2,393 chars

IN THE MATTER OF CHOI DOW IAN HONG & LEE ACCOUNTANCY

summary

The U.S. SEC charged Choi Dow Ian Hong & Lee Accountancy Corporation and its partner Ernest E. Dow, CPA, with willfully violating Section 102(a) of the Sarbanes-Oxley Act by issuing a 2004 audit report for a public company without PCAOB registration, leading to administrative proceedings seeking potential censure or permanent ban from practicing before the Commission.

paragraph

The U.S. Securities and Exchange Commission initiated administrative proceedings against Choi Dow Ian Hong & Lee Accountancy Corporation and Ernest E. Dow, CPA, for issuing an audit report on a public company’s 2004 financial statements without being registered with the Public Company Accounting Oversight Board (PCAOB), as required by Section 102(a) of the Sarbanes-Oxley Act since October 22, 2003. The SEC alleged that this conduct constituted a willful violation and rendered the firm and its partner unqualified to represent others before the Commission. No financial misstatements or monetary fraud were alleged; the charges focused solely on regulatory non-compliance under Section 4C of the Securities Exchange Act and Rule 102(e), with potential sanctions including censure or permanent denial of practice privileges.

narrative

The U.S. Securities and Exchange Commission (SEC) filed an administrative order against Choi Dow Ian Hong & Lee Accountancy Corporation and its partner, Ernest E. Dow, CPA, for violating Section 102(a) of the Sarbanes-Oxley Act by preparing and issuing an audit report on a public company’s 2004 financial statements without being registered with the Public Company Accounting Oversight Board (PCAOB), a requirement that took effect on October 22, 2003. The SEC alleged that this act was willful and rendered both the firm and Dow unqualified to practice before the Commission, as only PCAOB-registered firms may issue audit reports for public companies. No allegations of financial fraud, misstatement, or monetary loss were included—the charges were strictly procedural and regulatory in nature. The SEC invoked Section 4C of the Securities Exchange Act and Rule 102(e) of its Rules of Practice to initiate proceedings seeking potential censure or permanent bar from appearing or practicing before the Commission. A hearing was scheduled before an administrative law judge to determine the validity of the allegations and appropriate sanctions, with an initial decision required within 300 days of service. The case underscored the SEC’s enforcement of PCAOB registration mandates as a foundational element of audit integrity under Sarbanes-Oxley. Neither the firm nor Dow admitted guilt, and the outcome hinged on whether they could contest the willfulness of their non-compliance.

Enriched metadata

Scheme
unregistered-securities (100%)
Classified unregistered-securities(confidence 100%). EDGAR detection: forms Form D/S-1· recall 41% / precision 30%. detection rule →
Statutes
Section 4C of the Securities Exchange ActSection 4C(a)(1) of the Securities Exchange ActSection 4C(a)(1) of the Securities Exchange Act
Parties
Securities and Exchange CommissionChoi Dow Ian Hong & Lee Accountancy CorporationErnest E. Dow, CPA
Keywords
dowchoisecurities exchangeorderexchange commissionexchangecommissionmatter choicommission rulesrules practicesecuritiesmatterianhonglee

Extracted insights

Entities 4
  • person administrative law judge
  • company choi dow ian hong & lee accountancy corporation
  • person ernest e. dow
  • agency Securities and Exchange Commission
Triples 7
  • Securities And Exchange Commission announced issuance of an Order Instituting Administrative Proceedings
  • Choi Dow Ian Hong & Lee Accountancy Corporation prepared and issued an audit report on the financial statements of a public company in 2004
  • Ernest E. Dow participated in the preparation and issuance of an audit report
  • Sarbanes-Oxley Act prohibits accounting firms not registered with the Public Company Accounting Oversight Board from preparing or issuing audit reports
  • Choi Dow Ian Hong & Lee Accountancy Corporation willfully violated Section 102(a) of the Sarbanes-Oxley Act
  • Securities And Exchange Commission institutes proceedings against Choi Dow Ian Hong & Lee Accountancy Corporation and Ernest E. Dow
  • Administrative Law Judge directed to issue an initial decision no later than 300 days from the date of service
Text layers
Extracted body text (2,393c)

U.S. SECURITIES AND EXCHANGE COMMISSION 

Washington, D.C. 

SECURITIES EXCHANGE ACT OF 1934 
Release No. 56429 / September 13, 2007 
ACCOUNTING AND AUDITING ENFORCEMENT 
Release No. 2709 / September 13, 2007 
ADMINISTRATIVE PROCEEDING 
File No.3-12790 
IN THE MATTER OF CHOI DOW IAN HONG & LEE ACCOUNTANCY 
CORPORATION AND ERNEST E. DOW, CPA  
The United States Securities and Exchange Commission (Commission) announced the 
issuance of an Order Instituting Administrative Proceedings Pursuant to Section 4C of the 
Securities Exchange Act of 1934 and Rule 102(e) of the Commission’s Rules of Practice 
(Order) against Choi Dow Ian Hong & Lee Accountancy Corporation (Choi Dow) and 
Ernest E. Dow, CPA (Dow). 
The Order alleges that Choi Dow prepared and issued and Dow participated in the 
preparation and issuance of an audit report on the financial statements of a public company 
in 2004, without first registering with the Public Company Accounting Oversight Board 
(Board). Section 102(a) of the Sarbanes-Oxley Act of 2002 (Sarbanes-Oxley Act) 
prohibits accounting firms not registered with the Board from preparing or issuing audit 
reports with respect to any issuer after October 22, 2003.  The Order alleges that, by this 
conduct, Choi Dow and Dow lacked the requisite qualifications to represent others and that 
Choi Dow willfully violated Section 102(a) of the Sarbanes-Oxley Act.    
Based on the above, the Order institutes proceedings against Choi Dow and Dow pursuant 
to Section 4C(a)(1) of the Securities Exchange Act of 1934 (Exchange Act) and Rule 
102(e)(1)(i) of the Commission’s Rules of Practice, and additionally as to Choi Dow, 
Section 4C(a)(3) of the Exchange Act and Rule 102(e)(1)(iii) of the Commission’s Rules of 
Practice, to determine whether the allegations in the Order are true, and whether they should 
be censured or temporarily or permanently denied the privilege of appearing or practicing 
before the Commission as an accountant.   
A hearing will be scheduled before an administrative law judge to determine whether the 
allegations in the Order are true, to provide Choi Dow and Dow an opportunity to dispute 
these allegations, and to determine what sanctions, if any, are appropriate.  The Order directs 
the Administrative Law Judge to issue an initial decision in this matter no later than 300 
days from the date of service of the Order. 
OCR text (2,398c · tika · 95% conf)
U.S. SECURITIES AND EXCHANGE COMMISSION 

Washington, D.C. 


SECURITIES EXCHANGE ACT OF 1934 
Release No. 56429 / September 13, 2007 

ACCOUNTING AND AUDITING ENFORCEMENT 
Release No. 2709 / September 13, 2007 

ADMINISTRATIVE PROCEEDING 
File No.3-12790 

IN THE MATTER OF CHOI DOW IAN HONG & LEE ACCOUNTANCY 
CORPORATION AND ERNEST E. DOW, CPA  

The United States Securities and Exchange Commission (Commission) announced the 
issuance of an Order Instituting Administrative Proceedings Pursuant to Section 4C of the 
Securities Exchange Act of 1934 and Rule 102(e) of the Commission’s Rules of Practice 
(Order) against Choi Dow Ian Hong & Lee Accountancy Corporation (Choi Dow) and 
Ernest E. Dow, CPA (Dow). 

The Order alleges that Choi Dow prepared and issued and Dow participated in the 
preparation and issuance of an audit report on the financial statements of a public company 
in 2004, without first registering with the Public Company Accounting Oversight Board 
(Board). Section 102(a) of the Sarbanes-Oxley Act of 2002 (Sarbanes-Oxley Act) 
prohibits accounting firms not registered with the Board from preparing or issuing audit 
reports with respect to any issuer after October 22, 2003.  The Order alleges that, by this 
conduct, Choi Dow and Dow lacked the requisite qualifications to represent others and that 
Choi Dow willfully violated Section 102(a) of the Sarbanes-Oxley Act.    

Based on the above, the Order institutes proceedings against Choi Dow and Dow pursuant 
to Section 4C(a)(1) of the Securities Exchange Act of 1934 (Exchange Act) and Rule 
102(e)(1)(i) of the Commission’s Rules of Practice, and additionally as to Choi Dow, 
Section 4C(a)(3) of the Exchange Act and Rule 102(e)(1)(iii) of the Commission’s Rules of 
Practice, to determine whether the allegations in the Order are true, and whether they should 
be censured or temporarily or permanently denied the privilege of appearing or practicing 
before the Commission as an accountant.   

A hearing will be scheduled before an administrative law judge to determine whether the 
allegations in the Order are true, to provide Choi Dow and Dow an opportunity to dispute 
these allegations, and to determine what sanctions, if any, are appropriate.  The Order directs 
the Administrative Law Judge to issue an initial decision in this matter no later than 300 
days from the date of service of the Order.