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Overview
In our comment letter, we request that the SEC disapprove the PCAOB’s rule on firm and engagement metrics. We express our concerns that the rule’s swift adoption did not permit adequate study of its unintended consequences. We also highlight the potential disruption to the oversight of public company audits by independent audit committees established under the Sarbanes-Oxley Act, the likely misinterpretation of engagement metrics without appropriate context and an insufficient economic analysis to support the costs and benefits, as a result of the rule.