See “Cafeteria Conversation.” Steve has authority to write checks on the account of his employer, a public company under the Securities Exchange Act of 1934. Because Steve is a compulsive gambler and substance abuser, he needs a constant supply of cash to finance his habits. Steve regularly issues checks payable to actual suppliers who are not currently owed money. He then steals the checks, signs the names of the payees, and cashes the checks. Because Steve is also in charge of reconciling his employer’s bank statements, his embezzlement scheme is not discovered by the employer’s independent auditor during a routine audit. Is the independent auditor liable to the employer for its losses resulting from Steve’s embezzlement?