PwC submitted a comment letter supporting the PCAOB’s proposal to reorganize its existing interim and PCAOB-issued auditing standards into a topical structure with a single integrated numbering system, and to present the standards in a logical order that generally follows the flow of the audit process. In particular, we believe the proposed reorganization will help users navigate the board’s standards more easily.
However, we do not support the proposal to rescind AU 532, Restricting the Use of an Auditor’s Report, and the related proposed amendment to delete footnote 41 to paragraph 25 in Auditing Standard No. 16, Communications with Audit Committees, which could be interpreted to indicate that communications with audit committees should no longer be restricted.
We also believe it would be helpful if the board clarifies how amendments to existing standards in the framework will be reflected and whether the board will continue to retain superseded standards on its website. We also encourage the board to eliminate outdated references to accounting standards and references to generally accepted auditing standards in conjunction with its reorganization, and we offer some suggestions that may improve the alignment of the proposed reorganization with the flow of the audit process.