Trump Fraud Inquiry’s Focus: Did He Mislead His Own Accountants?

A spokeswoman for Mr. Trump’s accounting firm, Mazars USA, declined to comment beyond saying that it could not discuss its clients or its work for them without their consent, and that Mazars remained “committed to fulfilling all of our professional and legal obligations.” A lawyer for the firm, Jerry D. Bernstein, declined to elaborate.

A spokesman for the Manhattan district attorney’s office declined to comment.

If prosecutors determine that the statements were based on Mr. Trump’s own exaggerated claims, they could seize on a pattern of false valuations as evidence that he meant to mislead his accountants and lenders.

Mr. Trump did not personally assemble the data for the accountants, but the documents left no doubt as to who was accountable for their contents: “Donald J. Trump is responsible for the preparation and fair presentation of the financial statement in accordance with accounting principles generally accepted in the United States of America,” his accountants wrote in a cover letter attached to the statements in 2011 and 2012.

Yet the accountants also acknowledged they “have not audited or reviewed” the information and “do not express an opinion or provide any assurance about” it, a common caveat in statements of financial condition. The accountants disclosed that, while compiling the information for Mr. Trump, they had “become aware of departures from accounting principles generally accepted in the United States of America.”

Armed with those caveats, Mr. Trump’s lawyers would most likely argue that no one, let alone sophisticated lenders, should have taken his valuations at face value. And even if his valuations were false, the lawyers might argue, the lenders conducted their own analyses of Mr. Trump’s assets and concluded that he was a worthy borrower.

Mr. Trump’s lawyers could also call on people with expertise in property assessments to say that the value of a hotel or office building may be subject to various interpretations.

Mr. Trump, who has criticized Mr. Vance’s investigation as a political witch hunt, has deployed a similar defense in the past, chalking up any financial inconsistencies to “an innocent form of exaggeration,” as he called it in his 1987 book “The Art of the Deal.”