January 6, 2025
 

Comment Letter | SEC [Release No. 34-101724; File No. PCAOB-2024-06] PCAOB; Notice of Filing of Proposed Rules on FEM; PCAOB Rulemaking Docket Matter No. 041.

In this letter, we communicate our comments related to the SEC’s obligation to conduct economic analysis and our concerns regarding the Board’s lack of sufficient analysis and due process, and reiterate numerous concerns that we first raised in our comment letters related to the Firm and Engagement Metrics Proposal (PCAOB Release 2024-002 or Proposal), but that were not adequately addressed in the Final Rules adopted by the Board.

Read the full comment letter here.