Date: March 3, 2016

Issue: PCAOB

To: Mr. Brent J. Fields, Secretary, Securities and Exchange Commission

Filing Type: Regulatory 

Description: The CCMC believes that the Proposed Rules on Improving the Transparency of Audits: Rule to Require Disclosure of Certain Audit Participants on a New PCAOB Form and Related Amendments to Auditing Standards should not be adopted in their current form because they are not liability neutral. Additionally, we believe that the economic analysis is insufficient to justify an application of the rules to Emerging Growth Companies (“EGCs”). Finally, the CCMC also believes that establishing a 10-digit partner identifying number for a partner should not move forward as this was never subject to the notice and comment period for the PCAOB underlying rule.

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