The AICPA submitted its recommendations in response to the PCAOB's request for comments on its proposed rules for establishing auditing and other professional standards for auditors of public companies or issuers.

 

The AICPA encouraged the PCAOB to bring clarity to its standards-setting process for auditors of public companies or issuers. The Board should debate, develop and approve technical professional auditing and other standards in public meetings, provide adequate time for public comment on proposed standards, and address PCAOB process issues associated with cooperation and participation with international professional auditing and other standards, the AICPA said.

 

"We have always felt and will continue to believe that an open and public debate of the standards by the members of the standard setting body is in the public's best interest," William F. Ezzell, Chairman of the AICPA, and Barry C. Melancon, President and CEO of the AICPA, said in the letter to the PCAOB.

 

They went on to note that such open debate should include the opportunity for the public and the profession to observe and participate in the debate on a proposed standard, which would provide transparency as to why the Board takes a position.

 

Regarding the PCAOB's proposal to limit comments to 21 days, Ezzell and Melancon said, "The 21-day comment period is…in our view, insufficient to make public input meaningful." They said that while it may be possible to reduce the 60- to 90-day comment period typically used by other regulators, three weeks is "an unreasonably short period of time."

Ezzell and Melancon also said, "We believe the PCAOB should never issue a new or amended standard without a thorough due process, including an appropriate exposure period."

 

The AICPA, which represents 350,000 CPAs, has been stripped of its standard-setting power. In March, the Securities and Exchange Commission expressed its "concerns" regarding an AICPA press release announcing publication of exposure drafts of auditing and attest standards on internal control reporting. The watchdog agency reminded the accounting association that the PCAOB "may, but would not be required to, make use of those materials in formulating its proposals in this area."

 

The AICPA letter is available at: http://www.aicpa.org/download/sarbanes/2003_0512_cmmtltr_PCAOB_Rulemaking.pdf.