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Center for Audit Quality Asks PCAOB to Extend Comment Period for Two Proposed Standards

S.J. Steinhardt
Published Date:
May 23, 2024

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In a comment letter, the Center for Audit Quality (CAQ) asked the Public Companies Oversight Accounting Board (PCAOB) to extend its comment period for two proposed standards: Firm and Engagement Metrics and Firm Reporting. The CAQ also recommended that the PCAOB delay sending the 19b-4 filing form to the Securities and Exchange Commission (SEC) on standards QC 1000 and AS 1000—both of which the PCAOB approved on May 13—by at least 45 days. If the PCAOB has already filed the form, the CAQ recommended that it "withdraw and resubmit it in 45 days to allow ample time to review and consider the complex proposals and standards."  Accounting Today and CPA Practice Advisor both reported on this comment letter.

With regard to Firm and Engagement Metrics and Firm Reporting, the CAQ asked for an additional 60 days beyond the June 7 deadline—for a total of 120 days—to allow it to review and respond to these April 9 proposals. The Firm and Engagement Metrics standard would "require the reporting of specified firm-level metrics on new Form FM, Firm Metrics, and specified engagement-level metrics on an amended and renamed Form AP, Audit Participants and Metrics." The Firm Reporting standard would make changes "designed to improve and modernize reporting requirements; address potential gaps in the information available to the PCAOB, investors, audit committees, and other stakeholders; and facilitate more complete, standardized, and timely reporting of firm information."

"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 said in the comment letter. "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."

“Given the complexity and a significance of the proposals and simultaneous standard-setting activities, we find that a 60-day comment period does not provide sufficient time for stakeholders to provide the most comprehensive and meaningful feedback,” the CAQ stated.

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