PwC submitted a comment letter on the PCAOB’s Supplemental Request for Comment: Rules to Require Disclosure of Certain Audit Participants on a New PCAOB Form (the “Supplemental Request”). We are supportive of the proposal in the Supplemental Request to disclose the name of the engagement partner and information about certain other audit participants in a newly created PCAOB form (Form AP), rather than the auditor’s report. We believe this addresses in large measure the concerns we previously expressed regarding the proposal of disclosing this information within the auditor’s report. We appreciate the Board’s acknowledgement of the litigation risks created by a requirement to include information about the engagement partner and other audit participants in the auditor’s report, as well as the practical challenges that would result from the need to obtain consents from the named persons under section 7 of the Securities Act.
We have included certain recommendations, principally related to the execution and filing of Form AP.
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