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Comment Letter

CAQ provides views to the PCAOB related to its Release No. 2022-003, Draft 2022-2026 PCAOB Strategic Plan

Thursday, September 15, 2022

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In this comment letter, the CAQ provides views to the PCAOB related to its Release No. 2022-003, Draft 2022-2026 PCAOB Strategic Plan.

The CAQ is very supportive of the Board’s Draft Strategic Plan. The four goals to: 1) Modernize Standards, 2) Enhance Inspections, 3) Strengthen Enforcement, and 4) Improve Operational Effectiveness are important and will support the Board’s mission to protect investors and further the public interest in the preparation of informative, accurate, and independent audit reports. We are especially pleased to see the emphasis on stakeholder engagement as an organizational priority and as objectives for certain goals.

In our letter, we encourage the Board, among other things, to continue prioritizing its quality control project. We support and encourage stakeholder engagement throughout the standard-setting process as well as a standard’s entire lifecycle and encourage consideration of developments in other jurisdictions as collaboration among standard setters contributes to audit quality. We support a focus on data and technology. We observe that the PCAOB inspections process is widely and consistently viewed by audit firms and other U.S. capital markets stakeholders as robust and such inspections have over time enhanced audit quality. Among the objectives included Goal 2, we believe improving the timeliness of inspection reports is the most important. We support a balanced approach to enforcement. Further, we observe and appreciate – as part of the objective to Radically Improve the Employee Experience – the Board’s intent to “foster a diverse and inclusive workplace culture” among other ways to enhance its employees’ experience.