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And it also requires surprise audits in each state.
Three to five clerks were subjected to surprise audits every day, he said.
The surprise audits would allow independent accountants to review the books and verify that the money is there.
It remains to be seen whether typical independent accountants will be willing to provide the surprise audits required by the Custody Rule.
These procedures could include arrangements for more frequent surprise audits by specialized, independent accounting firms that have developed the necessary expertise.
Ms. Johnson said that surprise audits by the Transportation Security Administration as well as the company's own frequent internal inspections prevented the situations the employees described.
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Advisers to pooled investment vehicles are permitted to distribute audited financial statements in lieu of complying with the surprise audit requirement.
On Thursday your company will conduct a surprise audit.
Last year, James Wolfensohn, the Bank's boss, asked for a surprise audit of three countries Poland, Kenya and Pakistan to check that their loan books were clean.
Everyone Counts puts its machines through a rigorous auditing process, she said, and even interrupted a recent election in Australia to conduct a surprise audit in the middle of the ballot count.
"A surprise audit in the middle is interesting, but I don't think that's adequate for the job because there are still multiple ways to defeat it," Dill said.
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Justyna Jupowicz-Kozak
CEO of Professional Science Editing for Scientists @ prosciediting.com