In this comment letter, the CAQ responds to the SEC’s notice to solicit comment on QC 1000, A Firm’s System of Quality Control and Other Amendments to PCAOB Standards, Rules, and Forms, as adopted by the PCAOB Board.
In our letter we detail our views on the following:
- As we have consistently stated – including in encouraging the Board to move forward expeditiously with updating the US quality control standard to, in part, bring it up to date with the international standard – we believe that a firm’s quality control system is foundational to audit quality and that an effective quality control system is important to strengthening auditing practices and continuously improving audit quality. We also support the Board’s efforts to modernize existing auditing standards, and in particular quality control standards. We have supported this effort since responding to the PCAOB’s Concept Release on QC 1000 dated December 17, 2019, and Proposed Standard dated November 18, 2022.
- Unfortunately, we have specific concerns and questions about the Final Standard, particularly the new External Quality Control Function (EQCF), that we believe requires further consideration by the PCAOB before a final quality control standard can be approved by the SEC. Our comment letter focuses specifically on our concerns related to this new EQCF requirement.
Read the full comment letter here.