Comments: PCAOB proposal on firm metrics


In our comments responding to the PCAOB’s proposal on using firm and engagement metrics, we support the Board for pursuing meaningful transparency that will enhance the stakeholders’ understanding of audit firms and their engagements. However, we believe that additional study is needed in this area in order to determine which information is meaningful to the broader population of “stakeholders,” as described in the proposal.

Although we agree with the Board’s observation that audit quality cannot be wholly measured using calculated metrics, we note that the proposal currently includes 11 metrics with ambiguous intentions and usability. Other major observations outlined in the letter include the following:

  • We generally support reporting firm-level metrics and believe that certain changes to the proposed requirements would provide necessary clarity to stakeholders.
  • We believe no amount of context around engagement-level metrics would provide an appropriate basis for reporting such metrics publicly.
  • We believe the potential unintended consequences, such as diverting time away from audit quality as well as inappropriate or unsubstantiated inferences regarding the metrics, outweigh the intended benefit of the proposed metrics.

Download our letter to read our comments in full.


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