May 22, 2024

Comment Letter | Proposing Release: Firm and Engagement Metrics; PCAOB Rulemaking Docket Matter No. 041; Proposing Release: Firm Reporting; PCAOB Rulemaking Docket Matter No. 055

In this comment letter the CAQ formally requests that the Public Company Accounting Oversight Board (PCAOB or Board) extend the comment period for the PCAOB’s Proposing Releases, Firm and Engagement Metrics and Firm Reporting. We also recommend that the PCAOB delay sending the 19b-4 filing to the SEC on QC 1000 and AS 1000 by at least 45 days or, if already filed, withdraw and resubmit in 45 days to allow ample time to review and consider the complex proposals and standards.

As an organization dedicated to supporting and enhancing audit quality, we have been and continue to be supportive of the PCAOB’s strategic priorities, including their goal to modernize standards. The CAQ has the privilege of observing firsthand our member firms’ continued commitment to audit quality, and it is through that lens that we request this extension. An extension in the due date for comment letters will enable commenters to carefully consider the proposed requirements, including the impact of the final requirements included in recently adopted standards, and share thoughtful recommendations that will help the PCAOB finalize their standards and rules with requirements that have increased potential to improve audit quality while minimizing unintended  consequences.

We previously shared our support for the Board’s commitment to stakeholder engagement across its strategic goals. One way to demonstrate the Board’s commitment to stakeholder engagement with respect to standard  setting would be to extend the due date for comments on these proposals.