PwC generally supports the proposals and believes they will heighten the auditor's focus on the potential for material misstatement, particularly material misstatement due to fraud, arising from relationships and transactions with related parties, significant unusual transactions, and financial relationships and transactions with executive officers.
PwC believes that the audits of brokers and dealers should be conducted in accordance with PCAOB auditing and attestation standards once the SEC adopts Rule 17a-5 and, therefore, supports the changes to the Board's rules to reflect its pending jurisdiction over the auditors of brokers and dealers.
PwC commends the Board for issuing a re-proposal of the proposed standard and appreciate the Board's responsiveness in considering, addressing and providing feedback with respect to comments received on the original proposal. In the letter, PwC respectfully offers some suggestions that it believes will further improve the proposal.
Although supportive of the Board's objective, PwC is not convinced that these proposals will provide meaningful information to investors and other users of audit reports and enhance audit quality. PwC also believes that concerns remain about the potential litigation impact on the persons identified in the report. However, in the interest of promoting transparency in audits, PwC supports the identification of the engagement partner in Form 2.
PwC does not support mandatory audit firm rotation, a possible new requirement the Concept Release explores in-depth. There does not appear to be evidence of a correlation between extended audit tenure and diminished audit quality. PwC supports considering other alternatives to further enhance audit quality, including with respect to auditor independence, objectivity and professional skepticism, which build on reforms made thus far and focus on enhancing auditor and audit committee communications and disclosures.
PwC commends the PCAOB for its outreach to investors and others as a basis for developing the Concept Release and for its continued outreach via the public roundtable held on September 15, 2011. Results of that outreach clearly call for changes to the auditor's reporting model to increase its transparency and relevance. PwC believes the time is right for changes to the auditor's reporting model, and further agree with the Board that any change cannot compromise audit quality.
PwC believes that, consistent with the existing rule, the issuer, rather than the registered public accounting firm as is proposed, should be responsible for submitting notice to the PCAOB when a registered public accounting firm has signed an unqualified opinion or issued a consent to reissue a previously issued report in special circumstances when the issuer has outstanding a past-due share of the accounting support fee. If adopted as proposed, PwC asks that the Board explain its rationale for this change since its purpose is not clear.
The Concept Release requests comments on the concept of proposing rules requiring registered firms to make and document clear assignments of responsibility for implementation of Quality Control. Although supportive of the objective to clarify supervisory responsibilities, PwC does not believe separate rulemaking is necessary. Rather, the firm believes that this effort should be implemented through the quality control projects already on the Board's agenda. In addition, if the Board were to undertake separate rulemaking in this area, PwC supports a general framework of assignment and documentation rather than prescriptive rules.