Date: July 31, 2015

Issue: Accounting and Auditing

To: Ms. Phoebe Brown, Secretary, Public Company Accounting Oversight Board

Filing Type: Regulatory

Description: CCMC believes that the PCAOB has taken the appropriate steps to issue this Consultation Paper, but believe that a factual, evidentiary based decision process is needed to weigh a potential movement toward standard setting. As we have discussed in this letter, various tools, such as field testing, pre-implementation reviews and economic analysis, should be used to gather the information for a well-informed decision making process.

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