SEC resolution for PwC
Davis Polk represented PwC in connection with PwC’s resolution of a five-year investigation related to the provision of non-audit services to PwC’s SEC-registrant audit clients. The investigation, led by the Division of Enforcement of the Securities and Exchange Commission, was a significant independence-related investigation covering multiple years and numerous engagements.
PwC entered into the resolution without admitting or denying the SEC’s findings. Those findings related to 19 different engagements for 15 separate issuers. PwC agreed to pay a $3.5 million civil penalty and disgorge approximately $4.4 million (including prejudgment interest). In announcing the resolution, the SEC recognized PwC’s remedial efforts and its cooperation with the Commission staff during the investigation. PwC also agreed to certain Undertakings in connection with the resolution.