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Comment Letter

PCAOB Proposed Rule Governing Board Determinations Under the Holding Foreign Companies Accountable Act

Monday, July 12, 2021

In this comment letter, the CAQ provides views to the PCAOB related to its Proposed Rule Governing Board Determinations Under the Holding Foreign Companies Accountable Act (HFCAA). The proposed rule provides a framework for the PCAOB to use when determining, as contemplated under the HFCAA, whether the PCAOB is unable to inspect or investigate completely registered public accounting firms located in a foreign jurisdiction because of a position taken by one or more authorities in that jurisdiction.

The CAQ believes that high quality, reliable financial statements are the bedrock of our disclosure-based regulatory ecosystem, and audit quality is an important driver of high-quality financial disclosure. PCAOB inspections are a key component of the U.S. regulatory efforts to enhance the quality of financial reporting and ensure audit quality. With regards to the Proposed Rule, the CAQ provides input regarding consideration of confidential information, providing notification to registered firms about Board determinations, and supports firms having a right to request a re-evaluation of the Board’s determination when warranted.

Read the full comment letter here.

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