UNITED STATES OF AMERICA

before the

SECURITIES AND EXCHANGE COMMISSION

SECURITIES EXCHANGE ACT OF 1934

Release No. 98779 / October 23, 2023

ACCOUNTING AND AUDITING ENFORCEMENT

Release No. 4471 / October 23, 2023

ADMINISTRATIVE PROCEEDING

File No. 3-21784

In the Matter of

LUTHER C. SPEIGHT, III, CPA, AND

LUTHER SPEIGHT & COMPANY, 

LLC,

Respondents.

ORDER INSTITUTING PUBLIC

ADMINISTRATIVE PROCEEDINGS

PURSUANT TO RULE 102(e) OF THE 

COMMISSION’S RULES OF PRACTICE, 

MAKING FINDINGS, AND IMPOSING 

REMEDIAL SANCTIONS

I.

The Securities and Exchange Commission (“Commission”) deems it appropriate and in the 

public interest that public administrative proceedings be, and hereby are, instituted against Luther 

C. Speight, CPA (“Speight” or “Respondent”) and Luther Speight & Company (“LSC” or 

“Respondent”) (collectively, “Respondents”) pursuant to Rule 102(e)(3)(i) of the Commission’s 

Rules of Practice.1 

II.

In anticipation of the institution of these proceedings, Respondents have submitted an Offer 

of Settlement (the “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 

1 Rule 102(e)(3)(i) provides, in relevant part, that:

The Commission, with due regard to the public interest and without preliminary hearing, 

may, by order, . . . suspend from appearing or practicing before it any . . . accountant . . . who has 

been by name . . . permanently enjoined by any court of competent jurisdiction, by reason of his 

or her misconduct in an action brought by the Commission, from violating or aiding and abetting 

the violation of any provision of the Federal securities laws or of the rules and regulations 

thereunder.
2

Commission, or to which the Commission is a party, and without admitting or denying the findings 

herein, except as to the Commission’s jurisdiction over them and the subject matter of these 

proceedings, and the findings contained in Section III.3 below, which are admitted, Respondents

consent to the entry of this Order Instituting Public Administrative Proceedings Pursuant to Rule 

102(e) of the Commission’s Rules of Practice, Making Findings, and Imposing Remedial 

Sanctions (“Order”), as set forth below. 

III.

On the basis of this Order and Respondents’ Offer, the Commission finds that: 

1. Luther C. Speight, III (“Speight”), age 67, is a resident of New Orleans, 

Louisiana. Speight is a certified public accountant licensed in Louisiana, Tennessee and Georgia. 

He is the founder, 95% owner, and partner-in-charge of LSC, and managing partner on its audit 

engagements. 

2. Luther Speight & Company, LLC (“LSC”) is a Louisiana limited liability 

company based in New Orleans, LA. LSC is a certified public accounting and consulting firm that 

provides consulting, auditing and accounting services. 

3. On September 27, 2023, the Commission filed a complaint against Respondents in 

SEC v. Luther C. Speight, III and Luther Speight & Company, LLC (Civil Action No. 1:23-cv4384-AT). On October 4, 2023, the court entered an order permanently enjoining Respondents, by 

consent, from future violations of Sections 17(a)(2) and 17(a)(3) of the Securities Act of 1933. 

Speight was also enjoined from serving as the engagement manager, engagement partner, or 

engagement quality reviewer in connection with any audit of financial statements or audit report, 

which Speight should reasonably expect to be submitted to the Municipal Securities Rulemaking 

Board’s Electronic Municipal Market Access (“EMMA”) website, and LSC was enjoined from 

participating in the audit of financial statements which LSC should reasonably expect to be 

submitted to EMMA. Respondents were also ordered to pay, jointly and severally, disgorgement 

and prejudgment interest $14,961 and a civil penalty of $30,000. 

4. The Commission’s complaint alleged, among other things, that in connection with 

their audit of a school board’s financial statements, Respondents failed to perform their audit in 

accordance with Generally Accepted Auditing Standards (“GAAS”). The complaint alleged that, 

on January 2, 2020, LSC, through Speight, issued an auditor’s report stating that it had conducted 

the audit of the school board’s fiscal year 2019 financial statements in accordance with GAAS. 

The complaint alleged that that statement was false because Speight and LSC did not comply with 

GAAS in many important and material respects, and the financial statements also contained 

various errors that had to be corrected. The complaint alleged that Speight and LSC knew, or 

should have known, that their statement that they had performed their audit in accordance with 

GAAS was false and that the school board would use the auditor’s report to sell municipal bonds to 

investors. The complaint alleged that the school board unknowingly used the auditor’s report to 

sell $120 million of bonds to an investor in March 2020.
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IV.

In view of the foregoing, the Commission deems it appropriate and in the public interest to 

impose the sanction agreed to in Respondents’ Offer.

Accordingly, it is hereby ORDERED, effective immediately, that:

A. Speight is suspended from appearing or practicing before the Commission as an 

accountant.

B. LSC is suspended from appearing or practicing before the Commission as an 

accountant. 

C. After 3 years from the date of the Order, Speight may request that the Commission

consider Speight’s reinstatement by submitting an application to the attention of the Office of the 

Chief Accountant.

D. In support of any application for reinstatement to appear and practice before the 

Commission as a preparer or reviewer, or a person responsible for the preparation or review, of 

financial statements of a public company to be filed with the Commission, other than as a member 

of an audit committee, as that term is defined in Section 3(a)(58) of the Exchange Act, Speight

shall submit a written statement attesting to an undertaking to have Speight’s work reviewed by the 

independent audit committee of any public company for which Speight works or in some other 

manner acceptable to the Commission, as long as Speight practices before the Commission in this 

capacity and will comply with any Commission or other requirements related to the appearance and 

practice before the Commission as an accountant.

E. In support of any application for reinstatement to appear and practice before the 

Commission as a member of an audit committee, as that term is defined in Section 3(a)(58) of the 

Securities Exchange Act of 1934 (“Exchange Act”), as a preparer or reviewer, or as a person 

responsible for the preparation or review, of any public company’s financial statements that are 

filed with the Commission, Speight shall submit a statement prepared by the audit committee(s) 

with which Speight will be associated, including the following information:

1. A summary of the responsibilities and duties of the specific audit committee(s) 

with which Speight will be associated;

2. A description of Speight’s role on the specific audit committee(s) with which 

Speight will be associated;

3. A description of any policies, procedures, or controls designed to mitigate any 

potential risk to the Commission by such service; 

4. A description relating to the necessity of Speight’s service on the specific audit 

committee; and
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5. A statement noting whether Speight will be able to act unilaterally on behalf of 

the Audit Committee as a whole. 

F. In support of any application for reinstatement to appear and practice before the 

Commission as an independent accountant (auditor) before the Commission, Speight must be 

associated with a public accounting firm registered with the Public Company Accounting 

Oversight Board (the “PCAOB”) and Speight shall submit the following additional information:

1. A statement from the public accounting firm (the “Firm”) with which Speight is 

associated, stating that the firm is registered with the PCAOB in accordance 

with the Sarbanes-Oxley Act of 2002;

2. A statement from the Firm with which Speight is associated that the Firm has 

been inspected by the PCAOB and that the PCAOB did not identify any 

criticisms of or potential defects in the Firm’s quality control system that would 

indicate that Speight will not receive appropriate supervision; and

3. A statement from Speight indicating that the PCAOB has taken no disciplinary 

actions against Speight since seven (7) years prior to the date of the Order other 

than for the conduct that was the basis for the Order.

G. In support of any application for reinstatement, Speight shall provide 

documentation showing that Speight is currently licensed as a certified public accountant (“CPA”) 

and that Speight has resolved all other disciplinary issues with any applicable state boards of 

accountancy. If Speight is not currently licensed as a CPA, Speight shall provide documentation 

showing that Speight’s licensure is dependent upon reinstatement by the Commission. 

H. In support of any application for reinstatement, Speight shall also submit a signed 

affidavit truthfully stating, under penalty of perjury: 

1. That Speight has complied with the Commission suspension Order, and 

with any related orders and undertakings, including any orders in SEC v. 

Luther C. Speight, III and Luther Speight & Company, LLC, or any related

Commission proceedings, including any orders requiring payment of 

disgorgement or penalties;

2. That Speight undertakes to notify the Commission immediately in writing if 

any information submitted in support of the application for reinstatement 

becomes materially false or misleading or otherwise changes in any material 

way while the application is pending;

3. That Speight, since the entry of the Order, has not been convicted of a 

felony or a misdemeanor involving moral turpitude that would constitute a 
5

basis for a forthwith suspension from appearing or practicing before the 

Commission pursuant to Rule 102(e)(2); 

4. That Speight, since the entry of the Order:

a. has not been charged with a felony or a misdemeanor involving moral 

turpitude as set forth in Rule 102(e)(2) of the Commission’s Rules of 

Practice, except for any charge concerning the conduct that was the 

basis for the Order;

b. has not been found by the Commission or a court of the United States to 

have committed a violation of the federal securities laws, and has not 

been enjoined from violating the federal securities laws, except for any 

finding or injunction concerning the conduct that was the basis for the 

Order; 

c. has not been charged by the Commission or the United States with a 

violation of the federal securities laws, except for any charge concerning 

the conduct that was the basis for the Order;

d. has not been found by a court of the United States (or any agency of the 

United States) or any state, territory, district, commonwealth, or 

possession, or any bar thereof to have committed an offense (civil or 

criminal) involving moral turpitude, except for any finding concerning 

the conduct that was the basis for the Order; and

e. has not been charged by the United States (or any agency of the United 

States) or any state, territory, district, commonwealth, or possession, 

civilly or criminally, with having committed an act of moral turpitude, 

except for any charge concerning the conduct that was the basis for the 

Order.

5. That Speight’s conduct is not at issue in any pending investigation of the 

Commission’s Division of Enforcement, the PCAOB’s Division of 

Enforcement and Investigations, any criminal law enforcement 

investigation, or any pending proceeding of a State Board of Accountancy, 

except to the extent that such conduct concerns that which was the basis 

for the Order.

6. That Speight has complied with any and all orders, undertakings, or other 

remedial, disciplinary, or punitive sanctions resulting from any action taken 

by any State Board of Accountancy, or other regulatory body.

I. Speight shall also provide a detailed description of:
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1. Speight’s professional history since the imposition of the Order, including 

(a) all job titles, responsibilities and role at any employer;

(b) the identification and description of any work performed for entities 

regulated by the Commission, and the persons to whom Speight reported for 

such work; and

2. Speight’s plans for any future appearance or practice before the Commission.

J. The Commission may conduct its own investigation to determine if the foregoing 

attestations are accurate.

K. If Speight provides the documentation and attestations required in this Order and 

the Commission (1) discovers no contrary information therein, and (2) determines that Speight

truthfully and accurately attested to each of the items required in Speight’s affidavit, and the 

Commission discovers no information, including under Paragraph J, indicating that Speight has 

violated a federal securities law, rule or regulation or rule of professional conduct applicable to 

Speight since entry of the Order (other than by conduct underlying Speight’s original Rule 102(e) 

suspension), then, unless the Commission determines that reinstatement would not be in the public 

interest, the Commission shall reinstate the respondent for cause shown.

L. If Speight is not able to provide the documentation and truthful and accurate 

attestations required in this Order or if the Commission has discovered contrary information, 

including under Paragraph J, the burden shall be on Speight to provide an explanation as to the 

facts and circumstances pertaining to the matter setting forth why Speight believes cause for 

reinstatement nonetheless exists and reinstatement would not be contrary to the public interest. 

The Commission may then, in its discretion, reinstate Speight for cause shown. 

M. If the Commission declines to reinstate Speight pursuant to Paragraphs K and L, it 

may, at Speight’s request, hold a hearing to determine whether cause has been shown to permit 

Speight to resume appearing and practicing before the Commission as an accountant.

N. After 3 years from the date of the Order, LSC may request that the Commission 

consider LSC’s reinstatement by submitting an application to the attention of the Office of the 

Chief Accountant.

O. In support of any application for reinstatement to appear and practice before the 

Commission as a preparer or reviewer, or a person responsible for the preparation or review, of 

financial statements of a public company to be filed with the Commission, other than as a member 

of an audit committee, as that term is defined in Section 3(a)(58) of the Exchange Act, LSC shall 

submit a written statement attesting to an undertaking to have LSC’s work reviewed by the 

independent audit committee of any public company for which LSC works or in some other 

manner acceptable to the Commission, as long as LSC practices before the Commission in this 
7

capacity and will comply with any Commission or other requirements related to the appearance and 

practice before the Commission as an accountant.

P. In support of any application for reinstatement to appear and practice before the 

Commission as a member of an audit committee, as that term is defined in Section 3(a)(58) of 

Exchange Act, as a preparer or reviewer, or as a person responsible for the preparation or review, 

of any public company’s financial statements that are filed with the Commission, LSC shall submit 

a statement prepared by the audit committee(s) with which LSC will be associated, including the 

following information:

1. A summary of the responsibilities and duties of the specific audit committee(s) 

with which LSC will be associated;

2. A description of LSC’s role on the specific audit committee(s) with which LSC

will be associated;

3. A description of any policies, procedures, or controls designed to mitigate any 

potential risk to the Commission by such service; 

4. A description relating to the necessity of LSC’s service on the specific audit 

committee; and

5. A statement noting whether LSC will be able to act unilaterally on behalf of the 

Audit Committee as a whole. 

Q. In support of any application for reinstatement to appear and practice before the 

Commission as an independent accountant (auditor) before the Commission, LSC must be 

registered with the PCAOB and LSC shall submit the following additional information:

1. A statement regarding LSC’s legal status and whether it has merged or become 

affiliated with any other legal entity; 

2. A statement that LSC registered with the PCAOB in accordance with the 

Sarbanes-Oxley Act of 2002;

3. A statement that LSC has, within the prior one (1) year period hired an 

independent CPA consultant (the “Consultant”) who is not unacceptable to the 

staff of the Division of Enforcement of the Commission (the “Staff”) and is 

affiliated with a public accounting firm registered with the PCAOB, that has 

conducted a review of LSC’s quality control system, including the inspection 

and review of selected audit and review engagements of the firm over the past 

two annual periods preceding the commencement of the review, and other 

testing of the audit, supervisory, and quality control procedures of the firm as 

are necessary. The statement should further provide that the review did not 

identify any criticisms of or potential defects in LSC’s quality control system 
8

that would indicate that any of LSC’s associated persons will not receive 

appropriate supervision. LSC agrees to require the Consultant, if and when 

retained, to enter into an agreement that provides that for the period of review 

and for a period of two (2) years from completion of the review, the 

Consultant shall not enter into any employment, consultant, attorney-client, 

auditing or other professional relationship with LSC, or any of its present or 

former affiliates, directors, officers, employees, or agents acting in their 

capacity. The agreement will also provide that the Consultant will require that 

any firm with which they are affiliated or of which they are a member, and 

any person engaged to assist the Consultant in performance of their duties 

under this Order shall not, without prior consent of the Staff, enter into any 

employment, consultant, attorney-client, auditing or other professional 

relationship with LSC, or any of its present or former affiliates, directors, 

officers, employees, or agents acting in their capacity as such for the period of 

the review and for a period of two (2) years after the review; and 

4. A statement from LSC indicating that the PCAOB has taken no disciplinary 

actions against LSC since seven (7) years prior to the date of the Order other 

than for the conduct that was the basis for the Order.

R. In support of any application for reinstatement, LSC shall provide documentation 

showing that LSC is currently licensed as a CPA and that LSC has resolved all other disciplinary 

issues with any applicable state boards of accountancy. If LSC is not currently licensed as a CPA, 

LSC shall provide documentation showing that LSC’s licensure is dependent upon reinstatement 

by the Commission. 

S. In support of any application for reinstatement, LSC shall also submit a signed 

affidavit truthfully stating, under penalty of perjury: 

1. That LSC has complied with the Commission suspension Order, and with any 

related orders and undertakings, including any orders in SEC v. Luther C. 

Speight, III and Luther Speight & Company, LLC, or any related Commission 

proceedings, including any orders requiring payment of disgorgement or 

penalties;

2. That LSC undertakes to notify the Commission immediately in writing if any 

information submitted in support of the application for reinstatement becomes 

materially false or misleading or otherwise changes in any material way while 

the application is pending;

3. That LSC, since the entry of the Order, has not been convicted of a felony or a 

misdemeanor involving moral turpitude that would constitute a basis for a 

forthwith suspension from appearing or practicing before the Commission 

pursuant to Rule 102(e)(2); 
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4. That LSC, since the entry of the Order:

a. has not been charged with a felony or a misdemeanor involving moral 

turpitude as set forth in Rule 102(e)(2) of the Commission’s Rules of 

Practice, except for any charge concerning the conduct that was the 

basis for the Order;

b. has not been found by the Commission or a court of the United States to 

have committed a violation of the federal securities laws, and has not 

been enjoined from violating the federal securities laws, except for any 

finding or injunction concerning the conduct that was the basis for the

Order; 

c. has not been charged by the Commission or the United States with a 

violation of the federal securities laws, except for any charge concerning 

the conduct that was the basis for the Order;

d. has not been found by a court of the United States (or any agency of the 

United States) or any state, territory, district, commonwealth, or 

possession, or any bar thereof to have committed an offense (civil or 

criminal) involving moral turpitude, except for any finding concerning 

the conduct that was the basis for the Order; and

e. has not been charged by the United States (or any agency of the United 

States) or any state, territory, district, commonwealth, or possession, 

civilly or criminally, with having committed an act of moral turpitude, 

except for any charge concerning the conduct that was the basis for the 

Order.

5. That LSC’s conduct is not at issue in any pending investigation of the 

Commission’s Division of Enforcement, the PCAOB’s Division of 

Enforcement and Investigations, any criminal law enforcement investigation, 

or any pending proceeding of a State Board of Accountancy, except to the 

extent that such conduct concerns that which was the basis for the Order.

6. That none of LSC’s employees, partners, or professional staff’s conduct is at 

issue in any pending investigation of the Commission’s Division of 

Enforcement, the PCAOB’s Division of Enforcement and Investigations, any 

criminal law enforcement investigation, or any pending proceeding of a State 

Board of Accountancy, except to the extent that such conduct concerns that 

which was the basis for the Order.

7. That LSC has complied with any and all orders, undertakings, or other 

remedial, disciplinary, or punitive sanctions resulting from any action taken by 

any State Board of Accountancy, or other regulatory body.
10

T. LSC shall also provide a detailed description of:

1. LSC’s professional history since the imposition of the Order, including

(a) all engagements including audit and attestation work;

(b) the identification and description of any work performed for entities 

regulated by the Commission, and the primary contact person at 

such regulated entity; and

2. LSC’s plans for any future appearance or practice before the Commission.

U. The Commission may conduct its own investigation to determine if the foregoing 

attestations are accurate.

V. If LSC provides the documentation and attestations required in this Order and the 

Commission (1) discovers no contrary information therein, and (2) determines that LSC truthfully 

and accurately attested to each of the items required in LSC’s affidavit, and the Commission 

discovers no information, including under Paragraph U, indicating that LSC has violated a federal 

securities law, rule or regulation or rule of professional conduct applicable to LSC since entry of 

the Order (other than by conduct underlying LSC’s original Rule 102(e) suspension), then, unless 

the Commission determines that reinstatement would not be in the public interest, the Commission 

shall reinstate the respondent for cause shown.

W. If LSC is not able to provide the documentation and truthful and accurate 

attestations required in this Order or if the Commission has discovered contrary information, 

including under Paragraph U, the burden shall be on LSC to provide an explanation as to the facts 

and circumstances pertaining to the matter setting forth why LSC believes cause for reinstatement 

nonetheless exists and reinstatement would not be contrary to the public interest. The Commission 

may then, in its discretion, reinstate LSC for cause shown. 

X. If the Commission declines to reinstate LSC pursuant to Paragraphs V and W, it 

may, at LSC’s request, hold a hearing to determine whether cause has been shown to permit LSC 

to resume appearing and practicing before the Commission as an accountant.

By the Commission.

Vanessa A. Countryman

Secretary