The U.S. Chamber of Commerce’s Center for Capital Markets Competitiveness (“CCMC”) appreciates the opportunity to comment on the Public Company Accounting Oversight Board (“PCAOB” or the “Board”) Exposure Draft on A Firm’s System of Quality Control and Other Proposed Amendments to PCAOB Standards, Rules, and Forms (the “Exposure Draft,” the “Proposal,” or “QC 1000”). Quality controls (“QCs”) are foundational, as they provide an essential framework for effective audits.
The CCMC welcomes the effort by the PCAOB to update quality controls as the current standards were promulgated by the American Institute of Certified Public Accountants (“AICPA”) before the Sarbanes-Oxley Act of 2002 (“SOX”). Over the course of time, many changes have occurred in the financial reporting environment and the practice of public company auditing. Recently, audit firms, subject to PCAOB oversight, have invested substantial time and resources to achieve consistent, compliant, and effective implementation) of the updated global quality control standards of the International Auditing and Assurance Standards Board (“IAASB”) on an International Standard on Quality Management (“ISQM 1”) and have or are in the process of implementing the AICPA’s Statement on Quality Management Standards No. 1 (“SQMS 1”).