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Overview
In our comment letter, we express support for the PCAOB’s postponement of the effective date of QC 1000 due to the numerous implementation challenges and questions that have arisen primarily because of the differences between PCAOB QC 1000 and the IAASB quality control standard, International Standard on Quality Management (ISQM) 1, Quality Management for Firms that Perform Audits or Reviews of Financial Statements, or Other Assurance or Related Services Engagements.
In addition, we:
- Asked that the SEC encourage the PCAOB to reopen QC 1000 for comment
- Expressed our concerns about the external quality control function
- Suggested the evaluation framework be amended to be grounded in a risk-based approach
- Recommended revisions to the requirements for individuals assigned to certain roles specified in QC 1000.12
- Suggested changes to the documentation requirements in QC1000, including removing the experienced auditor threshold
- Recommended that the PCAOB allow firms to select their annual evaluation date
- Questioned whether the necessary revisions can be made in a one-year deferment period
- Suggested the PCAOB publish feedback received from stakeholder engagement and formalize a consultation process