

The bank bought subprime or high loan-to-value loans from large originators throughout the country. In 1992 the First National Bank of Keystone, then a small rural bank in West Virginia, sought to increase its revenues, launching an ambitious loan securitization program. We vacate the final decision and both orders, finding that when an accounting firm merely performs an external audit aimed solely at verifying the accuracy of a bank's books, it is not “participat” or “engaging” in “an unsafe or unsound practice in conducting the business” or “the affairs” of the bank, as those terms are used in 12 U.S.C. Grant Thornton also appeals the Comptroller's cease and desist order mandating that the firm comply with a host of conditions whenever it audits depository institutions. Grant Thornton, LLP, an accounting firm, appeals a final decision and order of the Comptroller of the Currency that requires the firm to pay $300,000 in civil penalties for recklessly failing to meet Generally Accepted Auditing Standards (“GAAS”) in its audit of the First National Bank of Keystone. Department of Treasury, argued the cause for respondent. Decided: February 08, 2008īefore: HENDERSON and TATEL, Circuit Judges, and WILLIAMS, Senior Circuit Judge. OFFICE OF the COMPTROLLER OF THE CURRENCY, Respondent. States Court of Appeals,District of Columbia Circuit. Grant Thornton complied with generally accepted government auditing standards and Uniform Guidance requirements when it performed the FY 2020 single audit of the USO.

The USO engaged Grant Thornton to perform its FY 2020 single audit. In FY 2020, the USO spent approximately $44 million on two DoD programs: the World-Wide DoD Military Services Support program and the Spirit of Hope Endowment. The USO is a congressionally chartered not-for-profit organization focused on keeping Service members connected to family, home, and country throughout their service to the Nation. The Uniform Guidance establishes the standards for obtaining consistency and uniformity among Federal agencies for the audit of non-Federal entities expending Federal awards. The Single Audit Act was enacted to promote sound financial management of Federal awards administered by non-Federal entities and to establish uniform requirements for audits of Federal awards. Non-Federal entities that expend Federal funds of $750,000 or more in a year are subject to the requirements of Public Law 104–156, “Single Audit Act Amendments of 1996” (the Single Audit Act), and title 2 Code of Federal Regulations part 200 (Uniform Guidance). (USO) in accordance with generally accepted government auditing standards and Federal requirements for single audits.


The objective of this quality control review was to determine whether Grant Thornton LLP (Grant Thornton) performed the FY 2020 single audit of the United Service Organizations, Inc.
