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Comment Letter

PCAOB: Estimates and Specialists Post-Implementation Review

Friday, June 10, 2022

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In this comment letter, the CAQ provides views to the PCAOB related to its Interim Analysis No. 2022-001, Post-Implementation Review, Estimates and Specialists Audit Requirements.

The CAQ continues to support outreach to monitor the implementation of the final standard and final amendments. We continue to support the principle of timely and robust post-implementation reviews, including a review approach that includes not only requests for public comment, but also analysis of other data and information. In recent years, accounting estimates, including fair value measurements, have become more prevalent and more significant, often having a significant impact on a company’s reported financial position and results of operations. Similarly, financial reporting increasingly involves application of specialized skills and knowledge. We believe that the increased attention to applying professional skepticism in the evaluation of accounting estimates, and the scalability and risk-based approach to using the work of specialists, bring positive improvements to audit quality.

In our letter, we applaud the PCAOB’s approach in working with the members of the profession, including meeting with CAQ task forces, as doing so allows for an ongoing dialogue on implementation. This dialogue was instrumental in permitting the profession to share specific feedback on unique implementation challenges and enabling the PCAOB staff to provide helpful clarification through guidance about the intent of the standards after they were finalized and before the effective date.