Date: August 15, 2016

Issue: Accounting and Auditing

To: Public Company Accounting Oversight Board (PCAOB)

Filing Type: Regulatory

Description: The CCMC is pleased that the PCAOB has dropped from the Proposal any new requirements on auditor responsibilities for other information outside the financial statements that were included in the prior proposal and is continuing research on these issues. However, the CCMC continues to have serious concerns regarding the Proposal, including that the Proposal

  1. blurs and even weakens lines of corporate governance, especially in cases where open communication may been needed between the audit committee and an external auditor;
  2. may create duplicative disclosures in many cases while risking auditors serving as original sources of information in others; and
  3. may raise the liability for auditors and businesses which ultimately harms investors.

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