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Comment Letter - PCAOB proposal on a firm’s system of quality control


In our comment letter on the quality control standard proposed by the Public Company Accounting Standards Board (PCAOB), we support the PCAOB’s overall objective of strengthening the requirements for a firm’s system of quality control and agree that the standard should use a risk-based approach similar to 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. However, we suggest that further alignment with ISQM 1, especially on the definitions of deficiencies, annual evaluation conclusions and the annual evaluation date, would serve the public interest by preventing confusion and complexity that could result if these provisions of the final PCAOB standard differ from those of ISQM 1.

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