The Public Accounting Firm Accounting Essay

The Public Accounting Firm Accounting Essay As an external auditor is required to be independent of the company when perform auditing services. If an auditor being to perform internal audit and management consulting services for the same company which they provided auditing services, there will have some issues arise. The issues included whether the auditor can be independent in mind and in appearance when providing such services. In US, there is prohibited the public accounting firm to provide non-audit services to an audit client. The arguments for the auditor should be allowed to perform these services for the same client is the auditor can work more efficiency by conduct both external and internal auditing services. They can reduce the time of work by eliminating overlapping work. Auditors will discover inefficiencies and other weaknesses while performing auditing service. When they discover such weaknesses, they can use the knowledge and expertise to provide the consulting services to management to improve such weaknesses. Besides that, by providing other services to same client, the company can save the time and money that would spend to obtain these services from another firm. The arguments for auditors should not be allowed to perform non-audit services for their audit client is they may not act independently in performing the external auditing services. The incentives of performing consulting and internal audit services will affect the judgment of the external audit. As we know internal audit services are best performed by the people who understand the culture and the operation of the company. Internal auditors are an important part of the corporate governance and should not be replaced by external auditor act as an internal auditor. A company will get more benefits from many different viewpoints. Therefore, company should obtain different entities to act as consultant and internal auditor to get multiple viewpoints. Explain how rules-based accounting standards differ from principles-based standards. How might fundamentally changing accounting standards from bright-line rules to principle-based standards help prevent another Enron-like fiasco in the future? Some argue that the trend toward adoption of international accounting standards represents a move toward more principles-based standards. Are there dangers in removing bright-line rules? What difficulties might be associated with such a change? Rules-based accounting standard are specific and detailed rules that must be followed when preparing companys financial statements. Principles-based standard is the general accepted accounting principles (GAAP) which used as a conceptual basis for accountants. It is general guidelines that describe the way classes of transactions should be reflected in general term. Principles-based may prevent another Enron issues by requiring accountants to make their professional judgments on the spirit of the law instead of just regarding technical compliance with the rules. In this case, for example, Enrons SPE, the manager may have succeeded in pressuring auditors to accept the deceptive financial reporting by pointing to the bright-line standard. However, the principles-based standard would require auditors to evaluate the situation of the company as a whole in order to determine whether the company did not have significant exposure in relation to the unconsolidated SPE. The dangers in removing the bright-line rule is in some situation will involve human judgment and discretion. Auditors may rationalize aggressive financial decisions. They will defend themselves when questioned by asseverate that the accounting standard did not prohibit their action. Enron and Andersen suffered severe consequences because of their perceived lack of integrity and damaged reputations. In fact, some people believe the fall of Enron occurred because of a form of run on the bank. Some argue that Andersen experienced a similar run on the bank as many top clients quickly dropped the firm in the wake of Enrons collapse. Is the run on the bank analogy valid for both firms? Why or why not? The run on the bank analogy is valid for both firms. Both of the firms are loss of confidence and credibility of investors and clients. Enron can avoid the bankruptcy if its customers willing to continue to use its services. The debt and obligations of the company are large but it also had large profit. The customers were not willing to use its services when Enron loss its credibility. Besides that, Andersen also can survive if Enron issue had been isolated. Andersen was a large and multinational firm. If it just loss of one client, Enron, it would not go to the end of the firm. However, once the Enron issue occurred, the clients of Andersen were loss of confidence in the firms credibility. As the result, many clients of Andersen had fired the firm as an external auditor of their company. Coopers Lybrand was sued under both federal statutory and state common law. The judge ruled that under Pennsylvania law the plaintiffs were not primary beneficiaries. Pennsylvania follows the legal precedent inherent in the Ultramares Case. (a) In jurisdictions following the Ultramares doctrine, under what conditions can auditors be held liable under common law to third parties who are not primary beneficiaries? (b) How do jurisdictions that follow the legal precedent inherent in the Rusch Factors case differ from jurisdictions following Ultramares? According to Ultramares cases, only the third parties who are primary beneficiaries can sue for ordinary negligence successfully. However, the third party who did not primary beneficiaries and did not have privity of contract also can successfully sue for gross negligence, recklessness and fraud. In this case, the creditors of Phar-Mor were not considered as primary beneficiaries. Therefore the creditors of Phar-Mor were needed to prove there had recklessness or fraud. Besides that, U.S. federal securities laws had required that recklessness needed be prove by a preponderance of the evidence, the Pennsylvania state common law had required prove by a clear and persuasive standard. According to Rusch Factors case, it had been broadened the Ultramares doctrine by allowed recovery by third party who are considered as foreseen users. A foreseen user is the limited class of users who the auditors were aware the user has the intention to rely on the financial statements. For example, the bank who lend loan to company will be a foreseen user. Coopers was also sued under the Securities Exchange Act of 1934. The burden of proof is not the same under the Securities Acts of 1933 and 1934. Identify the important differences and discuss the primary objective behind the differences in the laws (1933 and 1934) as they relate to auditor liability? For the case under the Securities Acts of 1933, the plaintiff have to prove that the audited financial statements were consisted material misstatement which caused the plaintiff suffered a loss. If the auditor faces an unusual burden of proof, auditor must demonstrate as a defense. The defenses are about the auditor had been conducted an adequate audit and the loss of plaintiff was caused by another reasons which other than the misleading financial statements. Under Securities Acts of 1934, the plaintiff must prove the reliance on financial statements where the financial statement consist material misstatement which caused in a loss. The Securities Acts 1933 had exposes the auditor to more litigation risk than the Securities Acts 1934. This change is to protect the buyers of new securities. In this case, even though neither Phar-Mors management, the plaintiffs attorneys, nor anyone else who associated with the case ever alleged the auditors knowingly participated in the fraud, a jury had found that Cooper liable under fraud claim. The important key of this fraud charge is the plaintiffs had been alleged that Cooper made representations which recklessly without regard to whether they were true or false. This had enabled plaintiffs to sue the auditors in term of fraud.

Ignorance Kills :: essays research papers

Any place I go, I know I will never find two skateboards that are the same. Each and every component of the skateboard makes a difference in the board’s movement. Every deck, truck, and wheel is interchangeable so there is almost an endless amount of combinations. A number of things can go wrong when riding; a person will never know when one of the components will malfunction. I was riding along one day, and like a cat pouncing on a mouse, it hits me and I suddenly realize that I am going to feel some pain. One of my wheels came off, I jerked, flew through the air, then landed on the street, all because the only day I took the time to check my wheels was the day I received the board. I can remember the first time I learned how to check and fix a skateboard. I learned from one of my good friend named James. He came to my house and we skated around for a little while. One of my wheels made a funny noise, and James said, "I think there is something wrong with your skateboard." We went into the garage and sat next to the washer and dryer. He then put the skateboard downside up, and started to examine the skateboard. He first looked at the deck to see if there was something wrong that could be making the noise. James studied the grip tape, looked at the tail and the nose, then the wood itself to see if it had been cracked or split. He then began talking to me about the trucks and their purpose; I studied and observed the hunks of metal. James then began to study the bearings and noticed that the bearings were extremely dirty. This was the cause of the noise. He told me that the bearings had to be clean. Too much friction was causing the noise. So James reached in his bag of tools, and got his mini monkey wrench and started to take off the nut that was holding the wheel to the truck. He was very precise, like a surgeon in heart surgery. With great ease he slipped off the wheel from the kingpin and placed it gentle on the floor. Once again James reached in his bag, grabbed a rag, and a special metal lubricate called Speedy Grease. Pop went the bearing as it came out of the wheel, I picked it up from the floor, pondered, and said, " hmmmm, to think that this little piece of machinery can actually effect the way the board operates, that this little piece is so important

Technological advances in society :: essays papers

Technological advances in society Technology enables students and teachers to have a fast and easy way to acquire unlimited access to tons of information. With all of the useful technologies, the curriculum is bound to change in endless ways, creating more opportunity for learning. It is very hard not to realize that technology has overpowered education in many ways. â€Å"Technology integration is similar to a tidal wave, growing silently in strength, then falling with an unstoppable roar upon those who paid no attention or showed little interest† (Guhlin, 40). Nowadays, computers are almost considered a necessity in the classroom, and are the main component of technology integration. Computers are being used in more numerous ways, besides only being used for basic word processing. With a simple computer, copious availabilities of technologies can be used in the classroom. â€Å"The one thing that is so great about the computer is that it does give a lot of instruction--and you don't need to have hearing to take advantage of it† (Anderson, 12). It’s amazing how one simple screen can provide everlasting opportunity for learning. One of the most widely used technologies is the Internet, or also known as the World Wide Web. â€Å"In August 1981 about 200 computers hosted Web servers. By July 1998 there were over 36 million Web servers, that are hosts to approximately 150 million people† (Strauss). The Internet proves to be very beneficial to education, since students have unlimited access to millions of websites with tons of information. There are only so many newspapers, journals and magazines that you can find in libraries or subscribe to. Therefore, the Internet offers an unlimited pile of information that students can always have. Moreover, students are enriched with the most current information in any subject, along with regular updates. Students are able to use the Internet anytime of day, as long as they have a computer at hand. The research process will not have to end when the school day is over (Wissick, 82). Along with using the World Wide Web for researching purposes, e-mail has become a very commonly used feature. Students and teachers can communicate outside of the classroom any time of day. In addition, this also opens up the idea of an online community center.

Air France-KLM Business Model Essay

A full service network carrier’s business model is typically based upon the operations of a hub-and-spoke route network (Vespermann & Holztrattner 2010). Air France-KLM group currently operates the largest network between Europe and the rest of the world. The network is coordinated around the two intercontinental hubs of Roissy-Charles de Gaulle and Amsterdam-Schiphol airports. These two hubs are organised in waves known as banks, combine connecting with point-to-point traffic. Air France-KLM group has a fleet of 573 aircraft which serves 253 destinations in 105 countries worldwide. Created by the merger of Air France and KLM in 2004, the Air France-KLM Group focuses its activities in 3 main areas: passenger, cargo and aeronautical maintenance. The passenger business is Air France-KLM’s main activity, contributing some 80% of the Group’s revenues. As a FSNC, the Group offers all type of route network including short, medium and long-haul. In which, the short and medium-haul network is a cornerstone of the Group’s development as its profitability has seen a significant deterioration since the 2009 crisis. Therefore, Air France-KLM is now offering new services to Business and Premium Economy customers together with new catering. Passengers now have access to catering inspired by the service on long-haul flights. Air France and KLM also continue to improve their levels of in-flight service. The Economy class will be innovated and upgraded with new in-flight entertainment systems. While the Business class offers its passengers a high standard of comfort and greater privacy with a redesigned World Business Class cabin including new seats which convert into fully flat beds, a choice of meal tray and time of meal service based on their individual needs. To facilitate and improve the airport experience for customers, Air France and KLM are developing the use of new technologies to enable boarding autonomy and streamlin e the baggage drop-off process. In June 2012, the two airlines decided to enhance their program for their frequent flyer customers by offering more reward ticket seat availability on the Air France and KLM European network and increasing the opportunities to earn miles. The Group is also one of the founding members of SkyTeam, which enables it to extend and consolidate its reach across 187 countries. The cargo business is the second of the Group’s activities, representing some 11% of the total revenues. Air France-KLM has a market share of 29.6% in 2012 amongst the Association of European Airlines (AEA) and 6.6% at global  level. During the financial year, the Group transported more than 1.4 million tons of cargo of which 66% in the passenger aircraft and 33 % in the dedicated cargo fleet, to a network of 251 destinations. In 2012, the new commercial strategy was deployed worldwide to improve efficiency and adapt to market conditions, and satisfy customers through more effective contractual conditions, adjusted customer segmentation, the implementation of a stronger key account team aligned with the organization of customers and the rationalization and simplification of the product portfolio. The acquisition of a 25% equity interest in Alit alia enables the Group to step up cooperation with the Italian airline and reinforce its presence in the Italian market, the fourth largest in Europe. Aircraft maintenance is the Air France-KLM Group’s third business. This activity generates more than one billion euros of revenue with third-party customers. Aircraft Maintenance is an attractive market despite the growing constraints which was led by the economic crisis, continued with the reduction in flight schedules, route closures and the early retirement of the oldest aircraft. Also aircraft, engine and equipment manufacturers are developing their after-sales services on this market by offering clients increasingly-integrated maintenance solutions. AFI KLM E&M is well known as the number two global player in the multi-product MRO area by total revenues. AFI KLM E&M’s primary task is to guarantee the airworthiness of the Group’s fleet and oversee regulatory compliance. With 75-year-plus track record, AFI KLM E&M has the large-scale human, technical and financial resources it needs to carry out the job in terms of maintaining the group’s fleets, and of being a flagship player in the global marketplace. Air France-KLM group h as one of the largest fleets in Europe with 605 aircraft, in which 573 were operational, the detail is as shown below: At December 31, 2012, 40% of the total Group fleet was fully owned, 22% under finance lease, and 38% under operating lease. The Air France-KLM Group’s pro-active fleet aimed at ensuring a fleet scaled in line with traffic growth and achieving technical consistency, while reducing its environmental impact. Source: Air France-KLM References: Vespermann, J & Holztrattner, S 2010, ‘The air transport system’, in A Wald, C Fay & R Gleich (eds), Introduction to aviation management, LIT Verlag, Mà ¼nster, Germany. Airfranceklm-finance.com, 2013, ‘Strategy, [in] Activity, Registration Document 2012, Labrador, Europe, viewed on 1 Apr 2014, Airfranceklm-finance.com, 2013, Air France-KLM Fleet, Air France – KLM, Europe, viewed on 1 Apr 2014, < http://www.airfranceklm-finance.com/en/content/download/7482/45417/file/Flotte_VA_31122012.pdf> Airfranceklm-finance.com, n.d., Air France – KLM: Profile and key figures – Group, Air France – KLM, viewed on 1 Apr 2014, Airfranceklm-finance.com, n.d., Air France – KLM: Passenger – Activities – Group, Air France – KLM, viewed on 1 Apr 2014 Airfranceklm-finance.com, n.d., Air France – KLM: Cargo – Activities – Group, Air France – KLM, viewed on 1 Apr 2014 Airfranceklm-finance.com, n.d., Air F rance – KLM: Maintenance – Activities – Group, Air France – KLM, viewed on 1 Apr 2014 Afiklmem.com, n.d., Air France Industries KLM Engineering & Maintenance – Overview, AFI KLM E&M, viewed on 1 Apr 2014 Afiklmem.com, n.d., Air France Industries KLM Engineering & Maintenance – Key Figures, AFI KLM E&M, viewed on 1 Apr 2014

Installation Art Essay

Out of the many ways in which we can view Installation Art, the term itself is not clearly defined. There are, however, different characteristics of it, and within this essay I will discuss the two most prevalent from my own point of view, and support my thoughts and opinions with examples from information we have encountered throughout this past semester. Although Installation Art has many qualities that it can be associated with, I believe that one which stands true above most is the fact that it Installation Art often casts the spectator as the protagonist. As we have seen throughout the semester, many different artist’s have employed their own ideas of what makes art Installation Art, yet from my own vantage point, it is only Installation Art if we create something for the spectator to walk into and ‘do’ something within the piece itself, as opposed to viewing it from a more museum like way, in order to create a more ‘authentic’ form of art. Lucas Samaras’s creation of ‘Room’, is a direct example of my thoughts on this characteristic of Installation Art. He wished to accommodate the viewer in his work. In this piece, he wished that the space of the piece become â€Å"a wholly immersive environment in which the space existed for the viewer to activate as an engaged and absorbed participant† (Bishop, 27). Installations should be geared toward first hand, real experiences by the viewer, and not illustrate simply a situation. Samaras’ ‘Room’ created this by having the items in the piece ‘fluid’, and not ‘glued-down’. ‘Room’, was a conglomeration of the artist’s own personal belongings reconstructed to mimic his own bedroom, in which the viewer could walk in, sit down on, and actually interact with the items, which, according to Samaras, created the ‘authentic’ quality of the art itself. As we view the characterstic of Installation Art as the spectator casted as the protagonist, we can now realize that, once again looking at Samaras’ ‘Room’, it addressed itself directly to the viewer, whose experience was not that of a detached onlooker, but was indeed the actual focus of the work itself. Samaras created a state of mind more than anything, in which the viewer was essentially in the first-person, and the subject actually will see things through their own ‘daydream’, which is nothing less than escape from a reality that is not completely suspended (in contrast to dreams while we are sleeping, in which we are suspended). According to Freud, a daydream is initially the expression of an unconscious fantasy, as a sort of ‘hallucinatory’ sense and is an escape from reality, which centers the viewer as the protagonist in the piece, because they are the one’s creating the art in which they see.

Large Intestine Essay

Many people often confuse the large intestine with the small intestine. However the large intestine is wider (about 3 inches) yet shorter than the small intestine  (in humans about 4. 9 feet in length as compared with 22 – 25 feet for the small intestine) and has a smooth inner wall. (Britannica)   Ã‚   The large intestine consists of the cecum, ascending, transverse, descending and sigmoid colon, rectum and anus. The longitudinal muscle of the muscularis  externa is concentrated into 3 bands called teniae coli. These 3 bands of muscle form pouches (haustra) because they are shorter than the rest of the colon. The epithelium of the mucosa is mostly goblet cells, and has a numerous  amount of crypts, there are no villi. (Martini, Ph. D. ) The ileocecal valve (sphincter) prevents materials from moving back into the ileum. In the upper half of the large intestine, enzymes from the small intestine complete the digestive process and bacteria produces the B vitamins (B12, thiamin, and riboflavin) as well as vitamin K. Martini, PhD) The large intestine’s primary function is to absorb water and electrolytes from digestive residues and storage of fecal matter until it can be expelled. The large intestine is the last attraction in digestive tube and the location of the terminal phases of digestion. In comparison to other regions of the tube, there are huge differences among species in the relative size and complexity of the large intestine. Nonetheless, in all species it functions in three processes:   (Marieb) *Recovery of water and electrolytes *Formation and storage of feces Microbial fermentation A wide variety of diseases and disorders occur in the large intestine. The most frequent and common disease of the large intestine is Crohn’s disease. The cause of Crohn’s disease is unknown. ( Britannica) Apart from the greater tendency for fistulas to form and for the wall of the intestine to thicken until the channel is obstructed, it is distinguishable from ulcerative colitis by microscopic findings. In Crohn’s disease, the maximum damage occurs beneath the mucosa, and lymphoid conglomerations, known as granulomata, are formed in the submucosa. Crohn’s disease attacks the perianal tissues more often than does ulcerative colitis. Although these two diseases are not common, they are disabling. ( Britannica) Because there is no specific etiology, a combination of anti-inflammatory drugs, including corticosteroids and aminosalicylic acid compounds, is used to treat Crohn’s disease. (Web MD) The drugs are effective both in treating acute episodes and in suppressing the disease over the long term. Depending on the circumstances, hematinics, vitamins, high-protein diets, and blood transfusions are also used. Surgical resection of the portion of the large bowel affected is often done. The entire colon may have to be removed and the small intestine brought out to the skin as an ileostomy an opening to serve as a substitute for the anus. In ulcerative colitis, as opposed to Crohn’s disease, the rectal muscle may be preserved and the ileum brought through it and joined to the anus. (Web MD) Lactose intolerance is the inability to digest significant amounts of lactose, the major sugar found in milk. Lactose intolerance is caused by a shortage of the enzyme lactase, which is produced by the cells that line the small intestine. Lactase breaks down milk sugar into two simpler forms of sugar called glucose and galactose, which are then absorbed into the bloodstream. Lactose intolerance is a problem caused by the digestive system. (lactose) People who do not have enough lactase to digest the amount of lactose they consume may feel very uncomfortable when they digest milk products.

Australia Law of North V Marra Developments Ltd †Free Samples

The leading case of North V Marra Developments Ltd (1981) was decided by the High Court of Australia on 9 th December 1981. The Hon’ble Stephen, Mason, Murphy, Aickin and Wilson JJ decided the case against the Appellant and in favor of the Respondant. As per the fact of the case, the Appellants are the member of a stock broking firm (Sydney Stock Exchange Ltd). The Appellants were initially trading in the name of NORTHS but are now considered as J. & J. NORTH. In 1954, Marra (Respondent) was incorporated as a public company. There were various rural properties that were acquired by Marra in 1974 in New South Wales. Its ninety three percent issued and paid up capital was held by 5 families. The shares of the company were listed on Sydney Stock Exchange. But, prior to 1974 the true value of the company assets were not depicted with the help of the balance sheets of the company or the market value of the assets. Considering with the situation, the Appellants in around December 1972-February 1974 submitted that there is a need that market capitalization of the asset must be done so that the true value of the Marra assets can be determined. There were three recommendations that were given by the Appellant and all the three were accepted by the Respondent. It is alleged by J. & J. NORTH that they have provided advisory services regarding the reorganization of the capital of Marra Developments Ltd. ("Marra") and advised on the takeover of Marra upon Scottish Australia Holdings Ltd. ("Scottish") and thus they are eligible for remunerations and the interest thereon from the Respondents. (Jade, 2017) Thus the main issue that was developed from the facts of the case was whether the Appellant is liable to claim the remuneration with interest from the Respondent. Now, because of the acts that are undertaken by the appellant and the Respondent, the major duty that was violated is submitted herein under. That the agreement amid the Appellant and the Respondent to carry out the scheme and the carrying out the scheme itself (of capitalization and takeover) are in violation of section 70 of the Securities Industry Act 1970 of New South Wales. The scheme itself and its conduct both are illegal in nature. (Armson, 2009) Because of the act, there is violation of section 1041A (Price Manipulation) and section 1041B of the Corporation Act 2001 (False Trading and Market Rigging). The main reason because of which the duties were considered to be violated are: The prices of the shares are increased by appellant involvement of buying the shares. The Appellant filed a case, however, the same is rejected by the Supreme Court of New South Wales. It is submitted but Meares J, that the argument of the defendant that the acts of the Appellant involves illegality is valid as the acts are in violation of section 70 of the Securities Industry Act 1970. The Appellant filed an appeal to the Court of Appeal. The Court of Appeal also dismissed the appeal of the appellant, Against the decisions of the Court of Appeal, the Appellant filed the present appeal. On 9 th December 1981 the Hon’ble Stephen, Mason, Murphy, Aickin and Wilson JJ submitted that the proposal which is recommended by the Appellant and which is later carried out by both the appellant and the defendant regarding the purchase/sale on the Stock Exchange in the Respondent is not found to be legal. It is decided that the agreement to carry out the scheme and the carrying out the scheme itself are in violation of section 70 of the Securities Industry Act 1970 of New South Wales. The scheme itself and its conduct both are illegal in nature. The court also held that the actions of the parties are not such which resulted in considering the same as conspiracy to deceive. Thus, the amount that is claimed by the Appellant cannot be recovered and the appeal stands dismissed.   The High Court decided that the amount that is claimed by the Appellant cannot be recovered and the appeal stands dismissed.   The main reasons that are attributed by the High Court which form the basis of the decision is submitted below and is critically analyzed: (O'Connell, 2013) In the Corporation Act 2001, considering the observations that are made Mason J and the changes under the 1980 Act, few variations were made regarding the market rigging and the false market provisions. There were few amendments that were made to section 998 of the corporation Act 2001. Because of the above facts, it is submitted by Mason J that any activity which gave the market false or misleading appearance is prohibited under statue. The acts of the appellant were against the statutory prohibition and thus the actions were illegal so they are not permitted to take advantage of any statutory wrong; These actions of the appellant were not regarded as legal in concern with section 70 of the 1970 act (E.T. Fisher &Co. Pty. Ltd. v. English Scottish and Australian Bank Ltd.  (1940). The actions of the Respondent with the help of the appellant which has resulted in enhancing the market price of the company of the respondent so that there is completion of takeover is an act which in contract to the provisions of section 70 of the Act. Thus, an illegal act cannot justify any benefits to be accrued in favor of the default. So, the appellant itself at fault cannot claim remuneration for an illegal act. The court held that the appeal of the appellant is not found to be favorable not because the agreement in which they are relying is in violation of section 70 but mainly because the actions in which they indulged into are itself illegal in nature. So, on those grounds it is decided by the High court that the appellant is not rightful in suing the Respondents and claim their remunerations on the basis that the acts in which they indulge into are itself illegal in nature. In the leading case there were series of observations that were made in relation to section 70 of the 1970 Act. Mainly the interpretation of the section signifies that there must be presence of some element in order for the application of the section. The   law submitted by Majon J is now not applicable in the current law . however, based on the observations that are made by the Hon’ble Judhe there were changes that were brought in Securities Industry Act 1980 (Cth) (1980 Act). (O'Connell, 2013) In the Corporation Act 2001, considering the observations that are made Mason J and the changes under the 1980 Act, few variations were made regarding the market rigging and the false market provisions. There were few amendments that were made to section 998 of the corporation Act 2001. However, again the market rigging and the false trading provisions were amended by the Financial Services Reform Act 2001 (Cth). The main changes that are brought in are that civil penalty provisions are made under Part 9.4B which includes few misconduct provisions inclusive of market rigging and false trading in (section 1041B of the corporation Act 2001) This change has reflect a doubt that it is very troublesome and expensive for the law to be applied by applying criminal standard of proof and it is more efficient and appropriate to apply the civil sanctions. Thus, now civil case can be brought which is based on the violation of section 1041B (1) by complying with civil standards of the balance of probabilities and there is no need for the establishment of any kind of fault or intention. Now if there is violation of section 1041 B (1) then a liability of @ $200,000 be imposed to an individual and @ $1 million for a body corporate. Thus, the leading case of North V Marra Developments Ltd and with the current reforms that are brought in then there is no need for the establishment of any kind of fault or intention. Ann O'Connell (2013) Protecting the Integrity of Securities Markets — What is an ‘Artificial Price’?: DPP (Cth) v JM, Melbourne Law School. Emma Armson (2009) False Trading and Market Rigging in Australia,   Corporate Law Teachers Association Conference, ANU College of Law. E.T. Fisher &Co. Pty. Ltd. v. English Scottish and Australian Bank Ltd.  (1940) 64 CLR 84 North V Marra Developments Ltd (1981). Scott v. Brown, Doering, McNab &Co.  (1892) 2 QB 724 Jade (2017) North V Marra Developments Ltd (1981) (Online). Available at: https://jade.io/article/66955. Accessed on 1st October 2017. Looking for an answer 'who will do my essay for cheap',