UNITED STATES OF AMERICA
Before the
SECURITIES AND EXCHANGE COMMISSION
SECURITIES EXCHANGE ACT OF 1934
Release No. 42936 / June 14, 2000
ACCOUNTING AND AUDITING ENFORCEMENT
Release No. 1275 / June 14, 2000
ADMINISTRATIVE PROCEEDING
File No. 3-10228
_________________________________________________________________
In the Matter of
MARY SATTLER POLVERARI,
C.P.A.,
Respondent.
_________________________________________________________________
ORDER INSTITUTING PUBLIC
ADMINISTRATIVE PROCEEDINGS
PURSUANT TO SECTION 21C OF THE
SECURITIES EXCHANGE ACT OF 1934,
AND RULE 102(e) OF THE COMMISSION'S
RULES OF PRACTICE, MAKING FINDINGS,
AND IMPOSING SANCTIONS AND
CEASE-AND-DESIST ORDER
I.
The Securities and Exchange Commission ("Commission") deems it
appropriate to institute public administrative proceedings pursuant to
Section 21C of the Securities Exchange Act of 1934 ("Exchange Act")
and Rule 102(e) of the Commission's Rules of Practice^ against Mary
Sattler Polverari ("Polverari" or "Respondent"), a certified public
accountant.
II.
In anticipation of the institution of these administrative
proceedings, Polverari has submitted an Offer of Settlement ("Offer")
which the Commission has determined to accept. Solely for the purpose
of these proceedings, and any other proceedings brought by or on
behalf of the Commission, or in which the Commission is a party,
SNIPPETS:
SECURITIES AND EXCHANGE COMMISSION
MARY SATTLER POLVERARI, C.P.A.,
ORDER INSTITUTING PUBLIC ADMINISTRATIVE PROCEEDINGS PURSUANT TO SECTION 21C OF THE SECURITIES
RULES OF PRACTICE, MAKING FINDINGS, AND IMPOSING SANCTIONS AND CEASE-AND-DESIST ORDER
The Securities and Exchange Commission deems it appropriate to institute public
In anticipation of the institution of these administrative proceedings, Polverari has
Solely for the purpose of these proceedings, and any other proceedings brought by or on
34 and Rule 102of the Commission's Rules of Practice, Making Findings, and Imposing Sanctions and
Mary Sattler Polverari, C.P.A., age 29, was hired as Supervisor of Financial Reporting at CUC
Polverari continued to hold that title after CUC became Cendant Corporation in December 1997.
Polverari is licensed as a certified public accountant in New York and resides in Brewster,
Cendant Corporation, a Delaware corporation with its headquarters in New York City, was
As of March 1, 2000, Cendant's common stock, Income PRIDES, and Growth PRIDES were registered
certain members of CUC's senior management implemented a scheme designed to ensure that CUC
As the scheme progressed over the course of several years, larger and larger year-end
As part of her duties, Polverari took those reporting packages and, using an electronic
At the end of each of the company's first three fiscal quarters each year, Polverari would
That is, the adjustments were simply entered into Polverari's spreadsheet at Stamford -- no
Polverari was never given any accounting rationale for the quarterly top-side adjustments she
For each of the first three quarters of a CUC fiscal year, once all the instructed
The managers directed that more than $50 million of these reversals were to be off-set by
Between Polverari's arrival at CUC in December 1995 and the discovery of the fraudulent
Section 10of the Exchange Act and Rule 10b-5 thereunder prohibit a person, in connection with
Based on the conduct described above, Polverari caused, and willfully aided and abetted, the
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