28. In 2007, M&A provided the PCAOB inspectors with copies of audit workpapers for the four audits discussed above. Almost a year later, M&A produced copies of audit workpapers for the same four audits in response to a PCAOB enforcement demand, but the workpapers were different - documents had been added and workpapers were initialed that were not previously initialed. Moore initially denied that any workpapers had been modified, but he was unable to explain the differences. Later, he attempted to explain the modifications away by referring to the second set of work papers (the workpapers produced in 2008) as "pro forma workpapers" intended to "demonstrate to enforcement that (M&A was) capable of performing a better job in documenting (its) work." The modifications did not comply with AS 3, however, because the modifications did not identify when the modifications were made, who made the modifications, or why the modifications were made. Moore also could not confirm that the original workpapers (i.e., the workpapers in existence at the documentation completion date and required to be retained for seven years) still existed.
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