Date: July 29, 2016

Issue: Accounting 

To: Pheobe Brown, Secretary, Public Company Accounting Oversight Board

Filing Type: Regulatory 

Description: The CCMC supports efforts to improve audit quality and effectiveness and appreciates the opportunity to comment on the Public Company Accounting Oversight Board (“PCAOB”) Proposed Amendments Relating to the Supervision of Audits Involving Other Auditors and Proposed Auditing Standard – Dividing Responsibility for the Audit with Another Accounting Firm (the “Proposal”). 

The Proposal would supersede or amend various existing PCAOB auditing standards related to the lead auditor’s supervision of other auditors who are not part of the audit firm issuing the audit report (whether other independent accountingfirms, including international network firms, or other individual accountants) and dividing responsibility for an audit with another accounting firm.  The CCMC has concerns about both the rationale for and approach of the Proposal, as well as the specifics regarding sufficiency determinations.

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