The PCAOB adopted rules that will allow certain registered firms to provide audit services without a break in their PCAOB registration status when there has been some change in their legal form.

Under section 102(a) of the Sarbanes- Oxley Act and PCAOB rules, a public accounting firm must be registered with the PCAOB to prepare or issue audit reports for public companies or to play a substantial role in such work. To become registered, an accounting firm files an application for registration on PCAOB Form 1, which the board may approve or disapprove. The new rules and form—PCAOB Form 4—identify circumstances in which the registration status of a registered firm may continue in effect even after the firm’s legal form has changed or the firm has combined with another firm, without the new legal entity needing to apply for registration on Form 1.

The rules would take effect 60 days after SEC approval. The text of the rules and the instructions to Form 4 can be found on the PCAOB Web site,, under the rulemaking docket.


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