Comment: SEC’s consideration of metrics reporting rules

 

In our comments to the SEC about approving the PCAOB’s recent rules on using firm and engagement metrics, we expressed support for the idea of firm-level metrics reporting, but note that the Board’s final rule requires eight calculated metrics that we believe have ambiguous intentions and usability. In fact, we do not believe the Board sufficiently articulated, in its adopting release, why the final rule is necessary and appropriately serves the public’s interest. In our view, the speed with which the final rule was approved suggests that sufficient due process was not undertaken, and we believe certain concerns raised by commenters, including tangible operational challenges, were not adequately addressed. For these reasons, we asked the SEC to withhold its approval of the final rule until some of these issues have indeed been addressed.

 

Download our letter to read our comments in full.