SUMMARY Recently, the International Ethics Standards Board for Accountants (IESBA) solicited public comments on its Consultation Paper, Improving the Structure of the Code of Ethics for Professional Accountants. This commentary summarizes the contributors' views on the various questions asked in the IESBA Consultation Paper. Our comments submitted to IESBA appear below. Data Availability: The invitation to comment (which invited comments through February 4, 2015), with links to the consultation paper, is available at: http://www.ifac.org/publications-resources/improving-structure-code-ethics-professional-accountants/.

Data availability: All data is available from public sources identified in the text. 1.Variable Descriptions: ΔCASH = The change in cash (∆Cash /Assets); WEAK (302/404) = 1 if Audit Analytics reports Section302 (or Section 404) ICW any of the years t, t-1, or t-2, = 0 otherwise; CFO = (Operating Cash Flow)/Assets; LMVE = Log (Market Value of Equity); LAGE = Log(firm age); TOBIN = (Tobin's Q), defined as (Market Value of Equity + Liabilities) / (Book Value of Equity + Liabilities); ILLIQ = (Amihud Illiquidity), defined as annual average of daily ratio of absolute value of daily CRSP stock returns to dollar volume: |Ret|/(dollar volume); INVEST = (Capital Expenditures + Research & Development Costs) / Assets; MTB = Market-to-book ratio; STDRET = Standard deviation of daily CRSP stock returns; LEV = Total Liabilities/ Total Assets; LOSS = 1 if ROA < 0, = 0 otherwise; LSEGM = Natural log of the number of segments (Compustat); FOREIGN = 1 if a firm reports income from foreign operations, = 0 otherwise; MA = 1 if Compustat reports a merger or acquisition during the year, = 0 otherwise; RESTRUCTURE = 1 if Compustat reports any restructuring charges during the year, = 0 otherwise; ΔEARN = annual change in firms' earnings, deflated by prior period total assets; ∆ALTMAN = Percentage change in a firm's Altman Z-Score; B5 = 1 if a firm is a Big N firm,= 0 otherwise; CASH = Firm's Cash balance (CHE) deflated by prior period assets; ∆SALE = Annual change in firms sales deflated by prior period assets; INVT = Inventory / Assets; AR = (Accounts Receivable) / Assets; RESTATE = 1 if a firm had a restatement indicated in Audit Analytics, = 0 otherwise.

served as an academic fellow at the U.S. Securities and Exchange Commission during 2016-17 academic year. The Securities and Exchange Commission, as a matter of policy, disclaims responsibility for any private publication or statement by any of its employees. The views expressed herein are those of the author and do not necessarily reflect the views of the Commission or of Dr. Pevzner's colleagues upon the staff of the Commission.

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