The SEC ought to reject the PCAOB’s proposed agency reporting mandates


Excessive-quality, impartial audits are important to investor safety and firms’ efforts to entry capital, and they aren’t attainable with out agency and truthful regulatory oversight.

On the American Institute of CPAs, the main member group for accounting professionals in the USA, we assist robust, clear and targeted regulation if it protects the investing public and the advantages outweigh the prices. Now we have deep concern about the price of sweeping guidelines adopted by the Public Firm Accounting Oversight Board on audit agency and audit engagement metrics, which — if permitted by the Securities and Trade Fee—would trigger many small and midsized audit companies to exit the general public firm market. 

The PCAOB’s guidelines would require companies that audit sure classes of public corporations to publicly report back to the board a spread of agency metrics together with trade expertise, workload, coaching hours, and associate and administration involvement, that are difficult to compile and of restricted utility. As well as, these metrics have to be reported on the engagement degree, too.  

Collectively, this knowledge can be open to misinterpretation with out context, pricey to implement, and probably at odds with consumer confidentiality agreements. The PCAOB hasn’t established the potential efficacy or demand for this sort of info by audit committees (which oversee auditors, monetary reporting and inside controls) or different stakeholders, and it has ignored requires a extra focused method. 

Nobody, together with the PCAOB, disputes {that a} mandate for brand new knowledge assortment methods and processes will add important prices, notably for smaller companies. But audit committees themselves say they’re at present getting all or a lot of the info they want from their auditors.

A possible contraction within the audit market and discount within the variety of companies that present companies are severe issues. If a single audit agency serving smaller corporations had been to exit the market, 10 issuers on common would want to discover a alternative auditor, calculations based mostly on publicly out there knowledge from Ideagen recommend. Multiply that impression by dozens of companies and it is clear the shifts may set off larger challenges and better prices in assembly mandatory audit necessities to entry U.S. capital markets.  

The PCAOB has described some mitigating components which will scale back the burden on smaller companies and the potential impression of companies exiting {the marketplace}. We discover most of them unpersuasive: Delaying the implementation time of the brand new guidelines, for instance, merely postpones the potential hurt. And the presumed reshuffling inside the market of public firm audit suppliers that the PCAOB predicts will happen to fill the void does not account for the specialization, assets and scalability required to satisfy crucial audit wants. 

Now we have different issues in regards to the PCAOB’s guidelines, together with the board’s choice to make use of the proposed metrics in its inspection and enforcement packages, growing the chance of penalties for minor, unintentional errors in reporting. Widespread sense would dictate some threshold for the severity of offense in reporting errors, however the board declined to impose one. The end result: increased dangers for companies and, with increased prices, decrease rewards. These are troubling and pointless indicators to ship in regards to the auditing occupation at a time when the CPA expertise pipeline is underneath stress.

CPAs play a crucial function in our capital markets, and we perceive and absolutely embrace that our auditing duties require strict oversight. However a cardinal check of any new regulation ought to be: “Do the advantages outweigh the potential penalties?” On this query, the PCAOB’s agency metrics guidelines fall quick, and the Securities and Trade Fee ought to both reject them outright or considerably revise them. 

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