Comment: PCAOB’s quality control standard

In our remarks responding to the SEC during the open comment period on the PCAOB’s final Quality Control Standard (QC 1000), we commend the PCAOB’s efforts in updating its quality control standards, especially considering the significant changes in the auditing landscape over the past two decades, and we offer some recommendations for the SEC to consider as it deliberates its approval of the final standard.

While QC 1000 contains a number of important components, we have concerns with the external quality control function (EQCF) within QC 1000. Specifically, we believe that stakeholders lacked the opportunity to provide feedback on the newly introduced EQCF role in the final standard, which is significantly more prescriptive than what the Board originally proposed. Further, we foresee operational issues that remain unaddressed, which could impact the successful implementation of QC 1000.

To read our comments in full, download our comment letter.