BEFORE THE CALIFORNIA BOARD OF ACCOUNTANCY DEPARTMENT OF CONSUMER AFFAIRS

STATE OF CALIFORNIA

In the Matter of the First Amended Accusation Against:

RONALDYEE PO Box 16056 San Francisco, CA 94116-0056

Certified Public Accountant Certificate No. CPA 77650

Respondent.

Case No. AC-2016-67

DECISION AND ORDER

The attached Stipulated Settlement and Disciplinary Order is hereby adopted by the

California Board of Accountancy, Department of Consumer Affairs, as its Decision in this

matter.

This Decision shall -become effective on [\{\{l\r(f\ · -~ 11D11

It is so ORDERED ·f.£X> 3 Q.b\1 . __

~p~:J

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KATHLEEN A KENEALY Acting Attorney General of California DlANN SOKOLOFF Supervising Deputy Attorney General SHE! LA J. VASANTHARAM Deputy Attorney General State Bar No. 289217

1515 Clay Street, 20th Floor P.0. Box 70550 Oakland) CA 94612-0550 Telephone: (51 0) 879" l 006 Facsimile: (51 0) 622-2270 E-mail: Sheila.Vasantharam@doj.ca.gov

Attorneys for Complainant

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8 BEFORE THE

9 CALIFORNIA BOARD OF ACCOUNTANCY DEPARTMENT OF CONSUMER AFFAIRS

STATE OF CALIFORNIA

0 Jn the Matter of the First Amended Accusation

12 Against:

13 RONALD VEE PO Box 16056

14 San Francisco, CA 94116-0056

Certified Pubiic Accountant Certificate No. CPA 77650

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Case No. AC-20 16-67

STJPUl.AT~D SKlTLEM~NT AND DISCIPLINARY ORDER

'

17 Respondent.

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19 IT IS HEREBY STIPULATED AND AGREED by and between the parties to the above~

entitled proceedings that the following matters are true:

22 L Patti Bowers (Complainant) is the Executive Officer of the California Board of

Accountancy (CBA). She brought this action solely in her official capacity and is represented in

this matter by Kathleen A. Kenealy, Acting Attorney General of the State of California, by Sheila

J. Vasantharam, Deputy Attorney GeneraL

2. Respondent Ronald Yee is representing himself in this proceeding and has chosen not

to exercise his right to be represented by counsel.

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3. On or about June 26, 1999, the CDA issued C~I'tific;;J PuLli~.,; A~.:~;uunlanl Cerlificate

No. CPA 77650 to Ronald Yee (Respondent). The Certified Public Accountant Certificate was in

full force and effect at all times relevant to the charges brm~ght in First Amended Accusation No.

AC-2016-67, and will expire on May 31,2018, unless renewed.

JURISDICTION

4. The First Amended Accusation No. AC-2016-67 was fi1ed before the CBA, and is

currently pending against Respondent. The First Amended Accusation and al1 other statutorily

required documents were properly served on Respondent on November 29, 2016. Respondent

timely filed his Notice of Defense contesting the First Amended Accusation.

5. A copy ofFirst Amended Accusation No. AC~2016-67 is attached as Exhibit A and

incorporated herein by reference.

ADVISEMENT AND WAIVERS

6. Respondent has carefully read> and understands the charges and allegations in First

Amended Accusation No. AC-2016-67. Respondent has also carefully read, and understands the

effects of this Stipulated Settlement and Disciplina_ry Order.

7. Respondent is fufiy. awareof his legal rights in this rnatier, including The right to a

hearing on the charges and aflegations in the First Amended Accusation; the right to be

represented by counsel at his own expense; the right to confront and cross-examine the witnesses

against him; the right to present evidence and to testify on his own behalf; the right to the

issuance ofsubpoenas to compel the a!tendance of witnesses and the production of documents;

the right to reconsideration and court review of an adverse decision; and all other rights accorded

by the California Administrative Procedure Act and other appiica.ble iaws,

8. Respondent voluntarily, knowingly) and intelligent1y waives and gives up each and

every right set forth above.

CULPABILITY

9. Respondent admits the truth of each and ev~ry charge and allegation in First

Amended Accusation No. AC-2016-67.

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10. Respondent agrees that his CertHied Public Accountant Certificate is subject to

discipline and he agrees to be bound by the CBA's probationary terms as set forth in the

Disciplinary Order below.

CONTINGENCY

11. This stipulation shall be subject to approval by the CBA. Respondent understands

and agre~s that counsel for Complainant and the staff of the CBA may communicate directly with

the CBA regarding this stipulation and settlement, without notice to or participation by

Respondent. By signing the stipulation, Respondent understands and agrees that he may not

withdraw his agreement or seek to rescind the stipulation prior to the time the CBA considers and

acts upon it. If the CBA fails to adopt this stipulation as its Decision and Order, the Stipulated

Settlement and Disciplinary Order shall be ofno force or effect, except for this paragraph, it shall

be inadmissible in any legal action between the parties, and the CBA shall not be disqualified

from further action by having considered this matter.

12. The parties understand and agree that Portable Document Format (PDF) and facsimile

copies of this Stipulated Settlement and Disciplinary Order, including PDF and facsimile

signature~thereto; shall have the same force and effect asthe originals.

13. This Stipulated Settleme,nt and Disciplinary Order is intended by the parties to be an

integrated writing representing the complete, final, and exclusive embodiment of their agreement.

It supersedes any and all prior or contemporaneous agreements, understandings, discussions,

negotiations, and commitments (written or oral). This Stipulated Settlement and Disciplinary

Order may not be altered, amended, modified> supplemented, or otherwise changed except by a

writing executed by an authorized representative of each of the partjes.

14. In consideration of the foregoing admissions and stipulations, the parties agree that

the CBA may" without further notice or formal proceeding, issue and enter the following

Disciplinary Order:

DISCIPLINARY ORDER

IT IS HEREBY ORDERED that Certified Public Accountant Certificate No. CPA 77650

issued to Respondent Ronald Yee is revoked. However, the revocation is st\':lyed and Respondent

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is placed on probation for three (3) years on the following terms and conditions.

l. Suspension

Certified Public Accountant Certificate No. CPA 77650 issued to Respondent Ronald Yee

is suspended for 90 days During the period of suspension Respondent shall engage in no .activities

for which certification as a Certified Public Accountant or Public Accountant is required as

described in Business and Professions Code, Division 3, Chapter 1, Section 5051.

2. Obey AU Laws

Respondent shall obey ·all federal, California, other states' and local laws, including those

rules relating to the practice of public accountancy in California.

3. Cost Reimbursement

Respondent shall reimburse the CBA $12,383.65 for its investigation and prosecution costs.

The payment shall be made in quarterly payments due with the quarterly written reports. The

final payment is due one year before the probation is scheduled to terminate.

4. Submit Written Reports

Respondent shall submit, within l 0 days of completion of the quarter, written reports to the

CBA on aform obtained from the CBA. Respondent shall submit; under penalty ofpetjury, such

othe:r written reports, declarations, and verification of actions as are required. These declarations

shall contain statements relative to Respondent's compliance with all the terms and conditions of

probation. Respondent shall immediately execute all release of information forms as may be

required by the CBA or its representatives.

5. Persona) Appearances

Rcspuw..lt;;ut shall, duriL1~ the peti.od of probation, appear in person ut 1ntorviowG/meetingG UG

directed by the CBA or its designated representatives, provided such notification is accomplished

in a timely manner.

6. Comply With Probation

Respondent shall fully comply with the terms and conditions of the probation imposed by

the CBA and shall cooperate fully with representatives of the CBA in its monitoring and

investigation ofRespo11dent's compliance with probation terms and conditions.

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7. Practice Investigation

Respondent shall be subject to 1 and shall permit, a practice investigation ofRespondenfs

professional practice. Such a practice investigation shall be conducted by representatives of the

CBA, provided notification of such review is accomplished in a timely marmer.

8. Comply With Citations

Respondent shall comply with all final orders resulting from citations issued by the CBA.

9. Tolling of Probation for Out~of-Statc Residence/Practice

In the event Respondent should leave California to reside or practice outside this state,

Respondent must notify the CBA in writing of the dates of departure and return. Periods of non·

California residency or practice outside the state shall not apply to reduction ofthc probationary

period, or of any suspension. No obligation imposed herein, including requirements to file

written reports, reimburse the CBA costs~ and make restitution to consumers, shall be suspended

or otherwise affected by such periods of out-of-state residency or practice except at the written

direction of the CBA.

10. Violation of Probation

If Respondent violates probation in any respect, theeBA, aftergiving Respondent notice

and an opportunity to be heard, may revoke probation and carry out the disciplinary order that

was stayed. If an accusation or a petition to revoke probation is filed against Respondent during

probation, the CBA shall have continuing jurisdiction until the matter is final, and the period of

probation shall be extended until the matter is final.

The CBA' s Executive Officer may issue a citation under California Code of Regulations,

Section 95, to a licensee for a violation of a term or condition contained in a decision placing that

licensee on probation.

11. Completion of Probation

Upon successful completion of probation, Respondent's licens~ will be fully restored.

12. Ethics Continuing Education

During the 90-day time period when Respondent's license is suspended, Respondent shall

complete four hours of continuing education in course subject matter pertaining to the following:

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a review ·of nationally recognized codes of conduct emphasizing how the codes relate to

professional responsibilities; case-based instruction focusing on real-life situational learning;

ethical dilemmas facing the accounting profession; or business ethics~ ethical sensitivity, and

consumer expectations. Courses must be a minimum of one hour as described in California Code

ofRegulations section 88.2. The hours shall be in addition to thos~ required for relicensing.

IfRespondent fails to complete said courses within the time period provided, Respondent

shall so notify the CBA and shall not resume practice until Respondent ·completes said courses,

has submitted proof of same to the CBA, and has been notified by the CBA that he may resume

practice. Failure to complete the required c·ourses no later than 180 days after the effective date

of the decision and order shall constitute a violation of probation.

13. Regulatory Review Course

During the 90-day time period when Respondent's license is suspendedi Respondent shall

complete a CBA-approved course on the provisions of the California Accountancy Act and the

California Board of Accountancy Regulations specific to the prac~ice ofpuhlic accountancy in

California emphasizing the provisions applicable to current practice situations. The course also

highlighting the misconduct which led to licensees being disciplined. The course shall be a

minimum of two hours. The hours shall be in addition to those required for relicensing.

If Respondent fails to complete said courses within the time period provided, Respondent

shall so notify the CBA and shall cease practice WltiJ Respondent completes said courses, has

submitted proof of same to the CBA, and has been notified by the CBA that he may resume

practice. Failure to complete the required courses no later than 180 days afler the effective date of

the decision and order shall constitute a violation ofprobation.

14. Acti-ve License Status

Respondent shall at all times maintain an active license status with the CBA, including

during any period of suspension. If the license is expired at the time the CBA's decision becomes

effective, the license must be renewed within 30 days of the effective date of the decision.

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15. Notification to Clients/Cessation of Practice

In orders that provide for a ·cessation or suspension ofpractice,. Respondent shall comply

with procedures provided by the CBA or its designee regarding notification to, and management

of, clients .

ACCEPTANCE

I have carefully read the Stipulated Settlement and Disciplinary Order. 1understand the

stipulation and the effect it will have on my Certified Public Accountant Certificate. I enter into

this Stipulated Settlement and Disciplinary Order voluntarily, knowingly, and intelligently, and

agree to be bound by the Decision and Order of the California Board of Accountancy.

11 DATED: "Ta.t'-'A«''Y Sth;2.o1l 12

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14 ENDORSEMENT

15 The foregoing Stipulated Settlement a.nd Disciplinary Order is hereby respectfully -- --~------·-------- -·--­

submitted for consideration by-the-Cs.Iffornii:Board of Aceouritancy. 16

17 Dated: \ / g'/1} Respectfully submitted,

KATHLEEN A. KENEALY Acting Attorne.y General of California DIANN SOKOL.OPF Supervising Deputy Attorney General

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21 SHEILA J. VASANTHARAM Deputy Attorney General Attorneys for Complainant

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KAMALA D. HARRIS Attorney General of California DIANN SOKOLOFF Supervising Deputy Attorney General . SHEILA J. VASANTHARAM Deputy Attorney General State Bar No. 289217

1515 Clay Street, 20th Floor P.O. Box 70550 Oakland, CA 94612-0550 Telephone: (51 0) 879-1006 Facsimile: (51 0) 622-2270 E-mail: Sheila.Vasantharam@doj .ca.gov

Attorneys for Complainant

BEFORE THE CALIFORNIA BOARD OF ACCOUNTANCY DEPARTMENT OF CONSUMER AFFAIRS

STATE OF CALIFORNIA

In the Matter ofthe First Amended Accusation Case No. AC-2016-67 Against:

FIRST

AMENDED

ACCUSATION

RONALD YEE PO Box 16056 San Francisco, CA 94116-0056

Certified Public Accountant Certificate No. CPA 77650

Respondent. ·

Complainant alleges:

PARTIES

1. Patti Bowers (Complainant) brings this First Amended Accusation solely in her

official capacity as the Executive Officer of the California Board of Accountancy, Department of

Consumer Affairs (CBA).

2. On or about June 26, 1999, the CBA issued Certified Public Accountant Certificate

Number CPA 77650 to Ronald Yee (Respondent). The Certified Public Accountant Certificate

was in full force and effect at all times relevant to the charges brought in this First Amended

Accusation and will expire on May 31, 2018, unless renewed.

Ill

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(RONALD YEE) FIRST AMENDED ACCUSATION

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JURISDICTION

3. This First Amended Accusation is brought before the CBA, under the authority of the

following laws. All section references are to the Business and Professions Code unless otherwise

indicated.

4. Section 5109 states:

"The expiration, cancellation, forfeiture, or suspension of a license, practice privilege, or

other authority to practice public accountancy by operation oflaw or by order ()r decision of the

board or a court oflaw, the placement of a license on a ret~red status, or the volmitary surrender

of a license by a licensee shall not deprive the board ofjurisdiction to commence or proceed with

any investigation of or action or disciplinary proceeding against the licensee, or to render a

decision suspending or revoking the license."

5. California Code ofRegulations, title 16, section 58, provides that licensees

engaged in the practice of public accountancy shall comply with all applicable professional

standards, including but not limited to generally accepted accounting principles and generally

accepted auditing standards.

STATUTORY PROVISIONS

6. Section 5051 states:

"Except as provided in Sections 5052 and 5053, a person shall be deemed to be engaged in

the practice of public accountancy within the meaning and intent of [Chapter 1 of Division 3

(commencing with Section 5000)] if he or she does any ofthe following:

"(a) Holds himself or herself out to the public in any manner as one skilled in the

knowledge, science, and practice of accounting, and as qualified and ready to render professional

service therein as a public accountant for compensation.

11 (b) Maintains an office for the transaction of business as a public accountant.

"(c) Offers to prospective clients to perform for compensation, or who does perform on

behalf of clients for compensation, professional services that involve or require an audit,

examination, verification, investigation, certification, presentation, or review of fin?-ncial

transactions and accounting records.

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(RONALD YEE) FIRST AMENDED ACCUSATION

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"(d) Prepares or certifies for clients reports cin audits or examinations ofbooks or records of

account, balance sheets, and other financial, accounting and related schedules, exhibits,

statements, or reports that are to be used for publication, for the purpose of obtaining credit, for

filing with a court of law or with any govenm1ental agency, or for any other purpose.

"(e) In general or as an incident to that work, renders professional services to clients for

compensation in any or all matters relating to a~counting procedure and to the recording,

presentation, or certification of financial information or data.

"(f) Keeps books, makes trial balances, or prepares statements, makes audits, or prepares

reports, all as a part of booldceeping operations for clients.

"(g) Prepares or signs, as the tax preparer, tax returns for clients.

"(h) Prepares personal financial or investment plans or provides to clients products or

services of others in implementation of personal financial or investment plans.

''(i) Provides management consulting services to clients.

"The activities set forth in subdivisions (f) to (i), inclusive, are 'public accountancy' only

when performed by a certified public accountant or public accou..11.tant, as defined in this chapter.

"A person is not engaged in the practice ofpublic~~countaJ:l.~y if the onl)r services he-or she

engages in are those defined by subdivisions (f) to (i), inclusive, and he or she does not hold

himself or herself out, solicit, or advertise for clients using the certified public accountant or

public accountant designation. Aperson is not holding himself or herself out, soliciting, or

advertising for clients within the meaning of this section solely by reason of displaying a CPA or

P A certificate in his or her office or identifying himself or herself as a CPA or P A on other than

signs, advertisements, letterhead, business cards, publications directed to clients or potential

clients, or financial or tax documents of a client."

7. Section 5100 states, in pertinent part:

"After notice and hearing the board may revoke, suspend, or refuse to renew any permit or

certificate granted under Article 4 (commencing with Section 5 070) and Article 5 (commencing

with Section 5080), or may censure the holder ofthat permit or certificate for unprofessional

conduct that includes, but is not limited to, one or any combination of the following causes:

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(RONALD YEE) FIRST AMENDED ACCUSATION

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"(h) Suspension or revocation of the right to practice before any governmental body or

agency.

'\l) The imposition of any discipline, penalty, or sanction on a registered public accounting

firm or any associated person of such firm, or both, or on any other holder of a permit, certificate,

license, or other authority to practice in this state, by the Public Company Accounting Oversight

Board or the United States Securities and Exchange Cmmnission, or their designees under the

Sarbanes-Oxley Act of 2002 or other federal legislation."

8. Section 5100.5, subdivision (a) ofthe Code states:

"After notice and hearing the board may, for unprofessional conduct, permanently restrict

or limit the practice of a licensee or impose a probationary term or condition on a license, which

prohibits the licensee from performing or engaging in any of the acts or services described in

Section 5051."

9. Section 5107(a) ofthe Code states:

"The executive officer of the board may request the administrative law judge, as part of the

proposed decision in a disciplinary proceeding, to direct any holder of a permit or certificate

found to have committed a violation or violations ofthis chapter to pay to the board all

reasonable costs of investigation and prosecution of the case, including, but not limited to,

attorney's fees. The board shall not recover costs incurred at the administrative hearing."

10. Section 5116 of the Code states, in pertinent part:

"(a) The board, after appropriate notice and an opportunity for hearing, may order any

licensee or applicant for licensure or examination to pay an administrative penalty as provided in

this article as part of any disciplinary proceeding or other proceeding provided for in this

chapter. 11

Ill

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(RONALD YEE) FIRST AMENDED ACCUSATION

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FACTUAL BACKGROUND

11. In April 2008, the Securities and Exchange Commission (SEC) initiated an

investigation into Respondent's activities. In mid-2009, the SEC asked Respondent to provide a

Wells Submission. 1

12. On or about October 30, 2009, the SEC filed a complaint against Respondent entitled

Securities and Exchange Commission v. King Chuen Tang, et al., Civ. Action No. 3:09-cv-05146­

JCS in the United States District Court for the Northern District of California. The SEC's

Complaint alleged, among other things, that in April2007, a venture capital fund (VCF)

employed Respondent as its Chief Financial Officer. In the course of his employment,

Respondent learned that the VCF had entered into an agreement to buy Acxiom Corporation

stock(Acxiom) and that the deal was in jeopardy. In'a breach of Yee's duties to the VCF,

Respondent conveyed this material, nonpublic information to an individual who then disclosed

the information to his friends and relatives. Based on the tip, these individuals short sold Acxiom

securities and realized approximately $6,018,610.00 in profits.

1 13. On or about 1v1arch 6, 2013, United States District Court for the Northern District of

California entered an order permanently resttaining and enjoining Respondent, by consent, from

violating Section 10, subdiv:ision (b) of the Securities Exchange Act of 1934 (the Exchange Act)

[15 U.S.C. § 78j, subd. (b)] and Rule 10b-5 promulgated thereunder [17 C.F.R. § 240.10b-5] by

using any means or instrumentality of interstate commerce, or of the mails, or of any facility of

any national securities exchange, in connection with the purchase or sale of any security: to ·

employ any device, scheme, or artifice to defraud; to make any untrue statement of a material fact

or to omit to state a material fact necessary in order to make the statements made, in light of the

circumstances under which they were made, not misleading; or engage in any act, practice, or

course of business which operates or would operate as a fraud or deceit upon any person. The

court also ordered that Respondent be found liable for a civil penalty in the amount of $62,545.66

pursuant to Section 21, subdivision (d)(3) of the Exchange Act [15 U.S.C. § 77u, subd. (d)(3)].

1 A Wells Submission allows an indi~idual to present facts and legal arguments to convince the SEC that it should not bring an action against the individual.

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(RONALD YEE) FIRST AMENDED ACCUSATION

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14. On March 13, 2013, Respondent signed the SEC's Offer of Settlement. Under this

agreement, Respondent consented to being barred, with the right of reentry after 5 years, from

association with any broker, dealer, investment adviser, municipal securities dealer, municipal

advisor, transfer agent, or nationally recognized statistical rating organization under Section 203,

subdivision (f) of the Advisers Act [15 U.S.C. § 80b-3, subd. (f)].

15. In March 2013, Respondent notified the CBA about the suspension of his right to

practice as a certified public accountant or public accountant before any goverm11ental body or

agency, the SEC's initiation of an investigation into his practice, the SEC's request for a Wells

Submission, and his civil settlement.

FIRST CAUSE FOR DISCIPLINE (Failure to Report Discipline to the Board)

(Bus. & Prof. Code,§ 5063, subds. (b)(3), (b)(4))

16. Respondent has subjected his Certified Public Accountant Certificate to disciplinary

action because he failed to report in writing to the Board within 3 0 days of his formal

investigation by the SEC, a governmental agency, and the SEC's request for a Wells Submission.

. (Bus. & Prof. Code, §5 061.) The circ111nstanc,es are setforth inparagraphs l1 through 15,

above.

SECOND CAUSE FOR DISCIPLINE (Suspension or Revocation of Right to Practice Before a Governmental Body)

(Bus. & Prof. Code,§ 5100, subd. (h))

17. Respondent has subjected his Certified Public Accountant Certificate to disciplinary

action because the SEC, a governmental body, suspended his right to practice in front of the SEC.

(Bus. & Prof. Code,§ 5100, subd. (h).) The circumstances are set forth in paragraph 14, above.

THIRD CAUSE FOR DISCIPLINE (Imposition of Discipline by the United States Securities and Exchange Commission)

(Bus. & Prof. Code, § 5100, subd. (l))

18. Respondent has subjected his Certified Public Accountant Certificate to disciplinary

action because the SEC disciplined Respondent by suspending him from appearing or practicing

before the SEC as an accountant. (Bus. & Prof. Code, § 5100, subd. (l).) The circumstances are

set forth in paragraphs 11 to 15, above.

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PRAYER

WHEREFOREl Complainant requests that a hearing be held on the matters alleged in this

First Amended Accusation, and that following the hearingl the California Board of Accountancy

issue a decision:

1. Revoking, suspending, restricting, limitingl or otherwise imposing discipline upon

Certified Public Accountant Certificate Number CPA 77650, issued to Ronald Yee;

2. Ordering Ronald Y ee to pay the California Board of Accountancy the reasonable

costs of the investigation and enforcement of this case, pursuant to Business and Professions

Code section 5.107;

3. Ordering Respondent to pay the California Board of Accountancy the administrative

penalties, pursuant to Business and Professions Code section5116; and

4. Taking such other and further action as deemed necessary and proper.

DA1ED: \\!lj'tt¥);­ ,.e.... i ~" - ---- - ~ -- -- ---- ­

.. ,,-ri

Executive Officer California Board of Accountancy Department of Consumer Affairs State of Callfornia Complainant

SF2016900l62 90716056.doc

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(RONALD YEE) FIRST AMENDED ACCUSATION