The U.S. Chamber of Commerce (“Chamber”) Center for Capital Markets
Competitiveness appreciates the opportunity to comment on the Public Company Accounting Oversight Board (“PCAOB” or “Board”) Exposure Draft on General Responsibilities of the Auditor in Conducting an Audit (“Exposure Draft” or “Proposal”). The Proposal is part of the Board’s standard-setting agenda to update and modernize PCAOB Auditing Standards (“AS”). The Chamber supports the PCAOB’s goal to update its auditing standards with thoughtful consideration and due process.

This standard-setting project focuses on the general principles and responsibilities of the auditor in conducting an audit. These principles and responsibilities are foundational and encompass extant PCAOB standards on reasonable assurance, due professional care, professional skepticism, independence, competence, and professional judgment.

According to the Executive Summary of the Proposal, the PCAOB is “reaffirming the general principles and responsibilities to ensure that the foundation continues to be solid and appropriate for maintaining high-quality audits.”

The proposed standard (“AS 1000”) and amendments would modernize PCAOB standards to “[r]eflect changes in the auditing environment; [e]liminate outdated and inconsistent language; and [a]chieve consistency with Board-issued standards.” These summarizations suggest that the Proposal is essentially a housekeeping exercise.