PwC comments on the SEC "Loan Provision" proposal

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Comment letter , PwC US Jun 29, 2018

We support the SEC’s effort to amend its independence rules regarding lending relationships.


PwC supports the SEC’s efforts to amend its auditor independence rules with respect to lending relationships with certain shareholders of an audit client (the “Loan Provision”), and has provided comments on various elements on the proposal. PwC’s comment letter expresses its support for the SEC’s objective of increasing the effectiveness of the rule without compromising auditor objectivity and impartiality.

PwC welcomes the SEC’s proposal as it mitigates a number of significant operational challenges and conceptual inconsistencies in the existing Loan Provision. In our comment letter, PwC suggests ways to more fully achieve the SEC’s stated objectives. PwC proposes limiting the scope of entities covered by the Loan Provision to “affiliates” to avoid hardship and overreach concerns and to maintain consistency within SEC independence rules. The letter also includes detailed comments on various other elements of the proposal. PwC also provided recommendations for improvements to several other areas of the SEC’s auditor independence rules.

Contact us

Heather Horn

Heather Horn

US Strategic Thought Leader, National Professional Services Group, PwC US

David Schmid

David Schmid

International Accounting Leader, National Professional Services Group, PwC US

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