Comment: PCAOB agenda priorities

In our response to the PCAOB’s request for comments on its future agenda priorities, we commend the Board for soliciting input before finalizing its agenda and confirm our alignment with the Board’s objective to focus on audit quality, investor protection, and the pursuit of moderate, sustainable standard setting that responds to stakeholders’ needs.

We encourage the Board to more broadly consider all stakeholders in its mission of protecting investors, which we believe would meaningfully enhance confidence in audit quality and financial reporting. We also ask the Board to provide additional opportunities for practitioner dialogue at all stages of the standard-setting process, from standards development through inspection and enforcement outcomes.

We further believe the Board could improve clarity in inspections by (1) revising the framework presented in Part I.A of inspection reports, and (2) maximizing the incorporation of the inspection of firms’ systems of quality control in the overall inspection process. This would encourage dialogue and provide further context and actionable information for all stakeholders who utilize the PCAOB’s inspection reports.

Finally, as audits continue to evolve in complexity and emerging technologies become more prevalent, we believe the PCAOB plays a critical role in enabling responsible innovation. We recommend that the Board issue clear, comprehensive, principle-based guidance on the auditor’s use of artificial intelligence and other emerging technologies to reduce uncertainty, promote consistency, and support thoughtful adoption by auditors.

We also encourage the Board to consider ways to deploy new technologies and modernize its oversight approach, such as leveraging firms’ systems of quality control, in order to make risk-based engagement selections for inspection, and to more efficiently analyze data in the comment letter process.

Download (PDF - 230.83KB) our comment letter to read our responses to specific queries posed by the PCAOB.